Non-discrimination: nationals and enterprises must not face more burdensome taxation in the other State under the treaty. Article 24 imposes a non-discrimination obligation preventing one Contracting State from subjecting nationals or enterprises of the other State to taxation or connected requirements that are other or more burdensome than those applied to its own nationals or similar domestic enterprises, including rules applicable to permanent establishments, while allowing exclusion of resident-only personal allowances and preservation of tax incentives limited to nationals.
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: nationals and enterprises must not face more burdensome taxation in the other State under the treaty.
Article 24 imposes a non-discrimination obligation preventing one Contracting State from subjecting nationals or enterprises of the other State to taxation or connected requirements that are other or more burdensome than those applied to its own nationals or similar domestic enterprises, including rules applicable to permanent establishments, while allowing exclusion of resident-only personal allowances and preservation of tax incentives limited to nationals.
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