Non-discrimination in taxation ensures taxpayers and permanent establishments receive no less favourable tax treatment than domestic counterparts. The Article requires that 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 that State's own nationals. It mandates that taxation of a permanent establishment be no less favourable than for domestic enterprises, allows host States to limit personal allowances to residents, ensures cross-border interest, royalties and similar payments are deductible on the same terms as domestic payments (subject to specific treaty exceptions), and applies non-discrimination to 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 in taxation ensures taxpayers and permanent establishments receive no less favourable tax treatment than domestic counterparts.
The Article requires that 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 that State's own nationals. It mandates that taxation of a permanent establishment be no less favourable than for domestic enterprises, allows host States to limit personal allowances to residents, ensures cross-border interest, royalties and similar payments are deductible on the same terms as domestic payments (subject to specific treaty exceptions), and applies non-discrimination to taxes of every kind.
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