Non-discrimination principle bars more burdensome taxation or related requirements on foreign nationals and enterprises in similar circumstances. 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 different or more burdensome than those applied to local nationals or similar enterprises in comparable circumstances; the rule covers permanent establishments, preserves a State's refusal to extend resident-only personal allowances to non-residents, and prohibits discriminatory treatment of enterprises controlled by residents of the other State, with 'taxation' limited to taxes covered by the Convention.
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 principle bars more burdensome taxation or related requirements on foreign nationals and enterprises in similar circumstances.
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 different or more burdensome than those applied to local nationals or similar enterprises in comparable circumstances; the rule covers permanent establishments, preserves a State's refusal to extend resident-only personal allowances to non-residents, and prohibits discriminatory treatment of enterprises controlled by residents of the other State, with "taxation" limited to taxes covered by the Convention.
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