Non-discrimination prevents tax measures treating foreign nationals or enterprises more burdensomely than comparable domestic taxpayers, including permanent establishments. Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or related requirements that are other or more burdensome than those applicable to nationals or similar domestic enterprises in the same circumstances; permanent establishments must be taxed no less favorably, differing tax rates alone do not constitute discrimination, personal allowances need not be extended to foreign residents, and interest, royalties and similar payments are deductible under the same conditions subject to specified exceptions. 'Taxation' means the taxes covered by the Agreement.
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 prevents tax measures treating foreign nationals or enterprises more burdensomely than comparable domestic taxpayers, including permanent establishments.
Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or related requirements that are other or more burdensome than those applicable to nationals or similar domestic enterprises in the same circumstances; permanent establishments must be taxed no less favorably, differing tax rates alone do not constitute discrimination, personal allowances need not be extended to foreign residents, and interest, royalties and similar payments are deductible under the same conditions subject to specified exceptions. "Taxation" means the taxes covered by the Agreement.
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