Non-discrimination: equal tax treatment for nationals and enterprises across contracting states, preventing more burdensome taxation. Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to comparable nationals or enterprises. Permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities, personal allowances may remain restricted, cross-border interest and royalties are deductible under the same conditions except for specified treaty exceptions, and ownership-controlled enterprises must not face more burdensome taxation. The provision covers taxes of every kind.
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: equal tax treatment for nationals and enterprises across contracting states, preventing more burdensome taxation.
Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to comparable nationals or enterprises. Permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities, personal allowances may remain restricted, cross-border interest and royalties are deductible under the same conditions except for specified treaty exceptions, and ownership-controlled enterprises must not face more burdensome taxation. The provision covers taxes of every kind.
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