Non-discrimination in taxation prevents unequal tax treatment of foreign nationals and enterprises under the treaty. Non-discrimination prohibits differential taxation or related requirements on nationals or persons of the other Contracting State in the same circumstances, extends to non-residents, mandates that permanent establishments be taxed no less favourably than domestic enterprises subject to specified exceptions, ensures deductibility of cross-border interest and royalties under the same conditions as domestic payments except where other treaty provisions apply, prevents more burdensome treatment of enterprises with foreign ownership or control, and applies to taxes of every kind and description.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Non-discrimination in taxation prevents unequal tax treatment of foreign nationals and enterprises under the treaty.
Non-discrimination prohibits differential taxation or related requirements on nationals or persons of the other Contracting State in the same circumstances, extends to non-residents, mandates that permanent establishments be taxed no less favourably than domestic enterprises subject to specified exceptions, ensures deductibility of cross-border interest and royalties under the same conditions as domestic payments except where other treaty provisions apply, prevents more burdensome treatment of enterprises with foreign ownership or control, and applies to taxes of every kind and description.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
