Non-discrimination in taxation prevents more burdensome tax treatment of foreign nationals and permanent establishments, with limited treaty exceptions. Non-discrimination prohibits a Contracting State from subjecting nationals of the other State to taxation or related requirements that are other or more burdensome than those applied to its own nationals; taxation of a permanent establishment of an enterprise of one State in the other must not be less favourable than taxation of domestic enterprises carrying on the same activities. The Article preserves denial of personal allowances tied to civil status, permits specified additional tax measures limited by the Agreement, and bars ownership-based discriminatory taxation against enterprises owned or controlled by residents of the other State.
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 more burdensome tax treatment of foreign nationals and permanent establishments, with limited treaty exceptions.
Non-discrimination prohibits a Contracting State from subjecting nationals of the other State to taxation or related requirements that are other or more burdensome than those applied to its own nationals; taxation of a permanent establishment of an enterprise of one State in the other must not be less favourable than taxation of domestic enterprises carrying on the same activities. The Article preserves denial of personal allowances tied to civil status, permits specified additional tax measures limited by the Agreement, and bars ownership-based discriminatory taxation against enterprises owned or controlled by residents of the other State.
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