Non-discrimination in taxation: foreign nationals and enterprises must not face more burdensome tax treatment than domestic counterparts. Non-discrimination prohibits more burdensome taxation or related requirements on nationals and specified persons of one Contracting State in the other State than those applied to domestic nationals in comparable circumstances. It ensures equivalent tax treatment for enterprises with permanent establishments and for related-party deductions of interest, royalties and debts, subject to enumerated exceptions and without obliging the grant of personal allowances tied to civil status or family responsibilities.
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: foreign nationals and enterprises must not face more burdensome tax treatment than domestic counterparts.
Non-discrimination prohibits more burdensome taxation or related requirements on nationals and specified persons of one Contracting State in the other State than those applied to domestic nationals in comparable circumstances. It ensures equivalent tax treatment for enterprises with permanent establishments and for related-party deductions of interest, royalties and debts, subject to enumerated exceptions and without obliging the grant of personal allowances tied to civil status or family responsibilities.
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