Non-discrimination obligations ensure equal taxation treatment for foreign nationals and enterprises under the treaty, including permanent establishments and cross-border payments. Non-discrimination obligations bar a Contracting State from imposing more burdensome taxation or related requirements on nationals and certain non-residents of the other Contracting State; permanent establishments must receive no less favourable tax treatment than domestic enterprises, subject to exceptions for personal allowances. Interest, royalties and similar payments to residents of the other Contracting State are deductible on the same conditions as if paid to domestic residents unless specified treaty provisions apply. Foreign-owned enterprises must not face discriminatory taxation compared with similar domestic enterprises.
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 obligations ensure equal taxation treatment for foreign nationals and enterprises under the treaty, including permanent establishments and cross-border payments.
Non-discrimination obligations bar a Contracting State from imposing more burdensome taxation or related requirements on nationals and certain non-residents of the other Contracting State; permanent establishments must receive no less favourable tax treatment than domestic enterprises, subject to exceptions for personal allowances. Interest, royalties and similar payments to residents of the other Contracting State are deductible on the same conditions as if paid to domestic residents unless specified treaty provisions apply. Foreign-owned enterprises must not face discriminatory taxation compared with similar domestic enterprises.
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