Non-discrimination in taxation ensures equal tax treatment for foreign nationals and enterprises, with limited exceptions for personal allowances. Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to comparable nationals or enterprises; permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities; personal allowances need not be extended to foreign residents; protections also cover enterprises owned or controlled by residents of the other State; 'taxation' means the taxes subject to 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 ensures equal tax treatment for foreign nationals and enterprises, with limited exceptions for personal allowances.
Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to comparable nationals or enterprises; permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities; personal allowances need not be extended to foreign residents; protections also cover enterprises owned or controlled by residents of the other State; "taxation" means the taxes subject to the Agreement.
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