Non-discrimination in taxation bars more burdensome tax treatment of foreign nationals, residents, and enterprise permanent establishments. Non-discrimination prohibits a Contracting State from imposing taxation or related requirements on nationals of the other State that are different or more burdensome than those on its own residents in similar circumstances; permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities; personal allowances reserved for residents need not be granted to non-residents; enterprises partly or wholly owned or controlled by residents of the other State must not face discriminatory taxation; '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 in taxation bars more burdensome tax treatment of foreign nationals, residents, and enterprise permanent establishments.
Non-discrimination prohibits a Contracting State from imposing taxation or related requirements on nationals of the other State that are different or more burdensome than those on its own residents in similar circumstances; permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities; personal allowances reserved for residents need not be granted to non-residents; enterprises partly or wholly owned or controlled by residents of the other State must not face discriminatory taxation; "taxation" means the taxes covered by the Agreement.
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