Non-discrimination: equal tax treatment for nationals and enterprises across contracting states, with limited allowance exceptions. Nationals and enterprises of one Contracting State must not face taxation or connected requirements in the other State that are different or more burdensome than those applied to the other State's nationals or similar domestic enterprises; personal allowances for residents need not be extended to non-residents; ownership by residents of the other State cannot justify discriminatory taxation; 'taxation' means the taxes covered by the Convention; an Indian resident company with a permanent establishment in Kenya may face an additional capped tax rate but must not be treated more burdensomely than similar Kenyan enterprises.
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 nationals and enterprises across contracting states, with limited allowance exceptions.
Nationals and enterprises of one Contracting State must not face taxation or connected requirements in the other State that are different or more burdensome than those applied to the other State's nationals or similar domestic enterprises; personal allowances for residents need not be extended to non-residents; ownership by residents of the other State cannot justify discriminatory taxation; "taxation" means the taxes covered by the Convention; an Indian resident company with a permanent establishment in Kenya may face an additional capped tax rate but must not be treated more burdensomely than similar Kenyan enterprises.
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