Non-discrimination in taxation: equal tax treatment for foreign nationals, enterprises and permanent establishments across the treaty. Non-discrimination prohibits less favourable taxation of nationals, resident-controlled enterprises and permanent establishments of one Contracting State in the other State compared with comparable domestic persons or enterprises. Enterprises with foreign ownership must not face discriminatory taxation or connected requirements. Except for specified exceptions, interest, royalties and other disbursements paid to residents of the other Contracting State are deductible for the payer under the same conditions as if paid to a domestic resident, and debts are deductible for determining taxable capital on the same basis as domestic debts.
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: equal tax treatment for foreign nationals, enterprises and permanent establishments across the treaty.
Non-discrimination prohibits less favourable taxation of nationals, resident-controlled enterprises and permanent establishments of one Contracting State in the other State compared with comparable domestic persons or enterprises. Enterprises with foreign ownership must not face discriminatory taxation or connected requirements. Except for specified exceptions, interest, royalties and other disbursements paid to residents of the other Contracting State are deductible for the payer under the same conditions as if paid to a domestic resident, and debts are deductible for determining taxable capital on the same basis as domestic debts.
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