Non-discrimination: equal tax treatment for foreign nationals and enterprises, barring more burdensome taxation or connected requirements. Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to that State's nationals; this extends to certain non-residents. Permanent establishments must be taxed no less favorably than domestic enterprises carrying on similar activities, with no obligation to grant personal allowances tied to civil status. Cross-border interest, royalties and disbursements are deductible under the same conditions as domestic payments except where specified exceptions apply. Enterprises owned or controlled by residents of the other State must not face more burdensome taxation. The Article covers taxes of every kind.
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: equal tax treatment for foreign nationals and enterprises, barring more burdensome taxation or connected requirements.
Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to that State's nationals; this extends to certain non-residents. Permanent establishments must be taxed no less favorably than domestic enterprises carrying on similar activities, with no obligation to grant personal allowances tied to civil status. Cross-border interest, royalties and disbursements are deductible under the same conditions as domestic payments except where specified exceptions apply. Enterprises owned or controlled by residents of the other State must not face more burdensome taxation. The Article covers taxes of every kind.
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