Non-discrimination in taxation ensures foreign nationals and enterprises face no more burdensome tax treatment than domestic counterparts. Non-discrimination requires nationals of one Contracting State not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to nationals of the other State, and this extends in certain cases to non-residents. The Convention requires equal treatment for taxation of permanent establishments, parity in deductibility of interest, royalties and debts for computing taxable profits and capital, and prohibits more burdensome taxation of enterprises owned or controlled by residents of the other State, while not obliging grant of personal allowances for family status to non-residents.
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 ensures foreign nationals and enterprises face no more burdensome tax treatment than domestic counterparts.
Non-discrimination requires nationals of one Contracting State not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to nationals of the other State, and this extends in certain cases to non-residents. The Convention requires equal treatment for taxation of permanent establishments, parity in deductibility of interest, royalties and debts for computing taxable profits and capital, and prohibits more burdensome taxation of enterprises owned or controlled by residents of the other State, while not obliging grant of personal allowances for family status to non-residents.
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