Non-discrimination ensures equal tax treatment for foreign nationals and enterprises under the treaty, subject to anti avoidance exceptions. Non-discrimination prohibits a Contracting State from subjecting nationals of the other State to taxation or related requirements more burdensome than those applied to its own nationals, extends to non-residents, requires not less favourable taxation of permanent establishments compared with domestic enterprises, ensures parity in deductibility of interest, royalties and other payments (subject to certain treaty provisions), protects enterprises owned or controlled by residents of the other State from discriminatory taxation, applies to all taxes, and excludes anti-avoidance measures, specified R&D incentives, and Exchange of Notes agreements.
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 ensures equal tax treatment for foreign nationals and enterprises under the treaty, subject to anti avoidance exceptions.
Non-discrimination prohibits a Contracting State from subjecting nationals of the other State to taxation or related requirements more burdensome than those applied to its own nationals, extends to non-residents, requires not less favourable taxation of permanent establishments compared with domestic enterprises, ensures parity in deductibility of interest, royalties and other payments (subject to certain treaty provisions), protects enterprises owned or controlled by residents of the other State from discriminatory taxation, applies to all taxes, and excludes anti-avoidance measures, specified R&D incentives, and Exchange of Notes agreements.
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