Non-discrimination in taxation ensures equal tax treatment for foreign nationals and enterprises, including permanent establishments. Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or connected requirements more burdensome than those applied to comparable nationals or enterprises; taxation of a permanent establishment must not be less favourably levied than taxation on domestic enterprises in like circumstances, while no obligation is imposed to extend resident-only personal allowances to non-residents; enterprises owned or controlled by residents of the other State must receive treatment no more burdensome than similar domestic enterprises. 'Taxation' is limited to taxes covered by the Convention.
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 equal tax treatment for foreign nationals and enterprises, including permanent establishments.
Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or connected requirements more burdensome than those applied to comparable nationals or enterprises; taxation of a permanent establishment must not be less favourably levied than taxation on domestic enterprises in like circumstances, while no obligation is imposed to extend resident-only personal allowances to non-residents; enterprises owned or controlled by residents of the other State must receive treatment no more burdensome than similar domestic enterprises. "Taxation" is limited to taxes covered by the Convention.
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