Non-discrimination: equal tax treatment mandated for nationals and enterprises to prevent more burdensome cross-border taxation. Non-discrimination requires that nationals and persons covered by the treaty not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to that State's nationals. Permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities, while resident-only personal allowances may be reserved. Payments such as interest and royalties paid to residents of the other State must be deductible under the same conditions as if paid to domestic residents, and debts to such residents treated similarly for taxable capital, subject to specified exceptions.
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 mandated for nationals and enterprises to prevent more burdensome cross-border taxation.
Non-discrimination requires that nationals and persons covered by the treaty not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to that State's nationals. Permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities, while resident-only personal allowances may be reserved. Payments such as interest and royalties paid to residents of the other State must be deductible under the same conditions as if paid to domestic residents, and debts to such residents treated similarly for taxable capital, subject to specified exceptions.
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