Non-discrimination in tax treaties ensures equal treatment of nationals, residents, permanent establishments and cross-border payments. Non-discrimination forbids differential taxation or related requirements against nationals, residents or stateless persons of the other Contracting State in comparable circumstances; it requires that taxation of a permanent establishment and treatment of payments and debts between enterprises and residents of the other State be no less favourable than for domestic counterparts, while allowing that personal allowances for residents need not be granted to non-residents.
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 tax treaties ensures equal treatment of nationals, residents, permanent establishments and cross-border payments.
Non-discrimination forbids differential taxation or related requirements against nationals, residents or stateless persons of the other Contracting State in comparable circumstances; it requires that taxation of a permanent establishment and treatment of payments and debts between enterprises and residents of the other State be no less favourable than for domestic counterparts, while allowing that personal allowances for residents need not be granted to non-residents.
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