Non-discrimination in tax treaties: equal tax treatment for foreign nationals and enterprises, including permanent establishments. Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to nationals of that other State; this extends to non-residents. Permanent establishments must not be taxed less favourably than domestic enterprises, subject to resident-specific personal allowances. Interest, royalties and similar payments to residents of the other State are deductible under the same conditions as if paid to domestic residents, except where specified exceptions apply. Ownership or control by residents of the other State shall not justify more burdensome taxation. The Article 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 tax treaties: equal tax treatment for foreign nationals and enterprises, including permanent establishments.
Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to nationals of that other State; this extends to non-residents. Permanent establishments must not be taxed less favourably than domestic enterprises, subject to resident-specific personal allowances. Interest, royalties and similar payments to residents of the other State are deductible under the same conditions as if paid to domestic residents, except where specified exceptions apply. Ownership or control by residents of the other State shall not justify more burdensome taxation. The Article applies to taxes of every kind and description.
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