Non-discrimination in taxation: cross-border taxpayers and enterprises must receive treatment no more burdensome than domestic counterparts. Non-discrimination requires that nationals or persons of one Contracting State shall not be subjected in the other Contracting State to taxation or related requirements that are more burdensome than those applied to nationals of that other State. Taxation of a permanent establishment must not be less favorably levied than on domestic enterprises carrying on the same activities, subject to specified exceptions. Interest, royalties and similar disbursements and enterprise debts to residents of the other State shall be deductible under the same conditions as if paid to residents, and enterprises with capital owned or controlled by residents of the other State shall not face more burdensome taxation.
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: cross-border taxpayers and enterprises must receive treatment no more burdensome than domestic counterparts.
Non-discrimination requires that nationals or persons of one Contracting State shall not be subjected in the other Contracting State to taxation or related requirements that are more burdensome than those applied to nationals of that other State. Taxation of a permanent establishment must not be less favorably levied than on domestic enterprises carrying on the same activities, subject to specified exceptions. Interest, royalties and similar disbursements and enterprise debts to residents of the other State shall be deductible under the same conditions as if paid to residents, and enterprises with capital owned or controlled by residents of the other State shall not face more burdensome taxation.
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