Non-discrimination in taxation: equal treatment of nationals and enterprises to prevent more burdensome tax measures across states. Article 24 mandates non-discrimination in taxation: nationals and nonresidents must not face taxation or related requirements that are different or more burdensome than those applied to comparable nationals; stateless residents receive equivalent protection. Permanent establishments of foreign enterprises must be taxed no less favourably than domestic counterparts, without obliging a State to grant personal civil-status allowances. Cross-border interest, royalties and debts must be deductible under the same conditions as domestic equivalents except where other provisions apply; enterprises with foreign ownership must not face more burdensome taxation. The Article applies to all taxes.
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Provisions expressly mentioned in the judgment/order text.
Non-discrimination in taxation: equal treatment of nationals and enterprises to prevent more burdensome tax measures across states.
Article 24 mandates non-discrimination in taxation: nationals and nonresidents must not face taxation or related requirements that are different or more burdensome than those applied to comparable nationals; stateless residents receive equivalent protection. Permanent establishments of foreign enterprises must be taxed no less favourably than domestic counterparts, without obliging a State to grant personal civil-status allowances. Cross-border interest, royalties and debts must be deductible under the same conditions as domestic equivalents except where other provisions apply; enterprises with foreign ownership must not face more burdensome taxation. The Article applies to all taxes.
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