Non-discrimination in taxation protects foreign nationals and enterprises from more burdensome tax treatment than comparable locals. Non-discrimination requires that nationals of one Contracting State not be subjected in the other Contracting State to taxation or related requirements that are other or more burdensome than those applicable to that other State's nationals in the same circumstances. The rule extends to enterprises and permanent establishments, which must not be taxed less favourably than domestic enterprises in similar activities and circumstances. The Article preserves an exception for residence-only personal allowances and protects enterprises owned or controlled by residents of the other Contracting State from discriminatory taxation; 'taxation' means taxes covered by the Agreement.
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 protects foreign nationals and enterprises from more burdensome tax treatment than comparable locals.
Non-discrimination requires that nationals of one Contracting State not be subjected in the other Contracting State to taxation or related requirements that are other or more burdensome than those applicable to that other State's nationals in the same circumstances. The rule extends to enterprises and permanent establishments, which must not be taxed less favourably than domestic enterprises in similar activities and circumstances. The Article preserves an exception for residence-only personal allowances and protects enterprises owned or controlled by residents of the other Contracting State from discriminatory taxation; "taxation" means taxes covered by the Agreement.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
