Non-discrimination: equal tax treatment for foreign nationals and enterprises, including parity for permanent establishments. Non-discrimination prohibits a Contracting State from subjecting nationals of the other State to taxation or connected requirements that are different or more burdensome than those applied to its own nationals in comparable circumstances, and this protection extends to non-residents. A permanent establishment must not be taxed less favourably than domestic enterprises carrying on similar activities; payments such as interest, royalties and fees to residents of the other State are deductible under the same conditions as if paid to residents, and debts to such residents are equally deductible for taxable capital.
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 foreign nationals and enterprises, including parity for permanent establishments.
Non-discrimination prohibits a Contracting State from subjecting nationals of the other State to taxation or connected requirements that are different or more burdensome than those applied to its own nationals in comparable circumstances, and this protection extends to non-residents. A permanent establishment must not be taxed less favourably than domestic enterprises carrying on similar activities; payments such as interest, royalties and fees to residents of the other State are deductible under the same conditions as if paid to residents, and debts to such residents are equally deductible for taxable capital.
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