Non-discrimination in tax treaties ensures nationals and enterprises receive no more burdensome taxation than comparable domestic counterparts. Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or related requirements more burdensome than those applied to that State's nationals in comparable circumstances, and extends to non-residents. Taxation of a permanent establishment of an enterprise must not be less favourably levied than on similar domestic enterprises, with a qualification permitting higher rates on foreign permanent establishment profits and without obliging States to grant resident-only personal allowances to non-residents. 'Taxation' means the 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 in tax treaties ensures nationals and enterprises receive no more burdensome taxation than comparable domestic counterparts.
Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or related requirements more burdensome than those applied to that State's nationals in comparable circumstances, and extends to non-residents. Taxation of a permanent establishment of an enterprise must not be less favourably levied than on similar domestic enterprises, with a qualification permitting higher rates on foreign permanent establishment profits and without obliging States to grant resident-only personal allowances to non-residents. "Taxation" means the taxes covered by the Convention.
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