Non-discrimination in tax treaties: equal taxation treatment for nationals, permanent establishments and controlled enterprises across borders. Non-discrimination requires nationals and non-residents of one Contracting State not be subject in the other State to taxation or related requirements that are more burdensome than those applicable to that State's nationals; this national treatment extends to all taxes. Permanent establishments of enterprises must not be taxed less favorably than domestic enterprises carrying on the same activities, subject to specified limitations. Enterprises owned or controlled by residents of the other State must not face more burdensome taxation than similar domestic enterprises. Inter-company interest, royalties and debts are deductible under the same conditions as if between domestic residents, except where specified exceptions apply.
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: equal taxation treatment for nationals, permanent establishments and controlled enterprises across borders.
Non-discrimination requires nationals and non-residents of one Contracting State not be subject in the other State to taxation or related requirements that are more burdensome than those applicable to that State's nationals; this national treatment extends to all taxes. Permanent establishments of enterprises must not be taxed less favorably than domestic enterprises carrying on the same activities, subject to specified limitations. Enterprises owned or controlled by residents of the other State must not face more burdensome taxation than similar domestic enterprises. Inter-company interest, royalties and debts are deductible under the same conditions as if between domestic residents, except where specified exceptions apply.
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