Non-discrimination in tax treatment prevents differential taxation of nationals and enterprises under bilateral tax agreements. Non-discrimination prohibits a Contracting State from imposing taxation or connected requirements on nationals of the other State that are different or more burdensome than those on its own nationals; it requires parity in taxation of permanent establishments, equal deductibility of payments and debts to residents of the other State (subject to specific treaty exceptions), and equal treatment of enterprises owned or controlled by residents of the other State, applying to all taxes.
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 tax treatment prevents differential taxation of nationals and enterprises under bilateral tax agreements.
Non-discrimination prohibits a Contracting State from imposing taxation or connected requirements on nationals of the other State that are different or more burdensome than those on its own nationals; it requires parity in taxation of permanent establishments, equal deductibility of payments and debts to residents of the other State (subject to specific treaty exceptions), and equal treatment of enterprises owned or controlled by residents of the other State, applying to all taxes.
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