Non-discrimination in tax treaties ensures equal tax treatment for foreign nationals and enterprises, including permanent establishments and deductions. Non-discrimination prohibits differing or more burdensome taxation of nationals of one Contracting State by the other, applies to non-residents as well, requires that taxation of permanent establishments be no less favourable than that of domestic enterprises, ensures deductibility of interest, royalties and debts on the same conditions as if paid to residents (subject to specified exceptions), and forbids discriminatory taxation or requirements against enterprises owned or controlled by residents of the other Contracting 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 tax treaties ensures equal tax treatment for foreign nationals and enterprises, including permanent establishments and deductions.
Non-discrimination prohibits differing or more burdensome taxation of nationals of one Contracting State by the other, applies to non-residents as well, requires that taxation of permanent establishments be no less favourable than that of domestic enterprises, ensures deductibility of interest, royalties and debts on the same conditions as if paid to residents (subject to specified exceptions), and forbids discriminatory taxation or requirements against enterprises owned or controlled by residents of the other Contracting State.
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