Non-discrimination protection ensures equal tax treatment for foreign nationals and enterprises under the treaty, subject to specific exceptions. The Article establishes non-discrimination protections: nationals and non-residents must not be taxed or subjected to connected requirements more burdensomely than nationals in comparable circumstances; permanent establishments must be taxed no less favorably than domestic enterprises carrying on the same activities (subject to allowances and certain rate distinctions); cross-border payments are deductible on equal terms except where other treaty provisions apply; and enterprises owned or controlled by residents of the other Contracting State must not face more burdensome taxation than similar domestic enterprises. Protections cover only taxes within the Agreement.
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 protection ensures equal tax treatment for foreign nationals and enterprises under the treaty, subject to specific exceptions.
The Article establishes non-discrimination protections: nationals and non-residents must not be taxed or subjected to connected requirements more burdensomely than nationals in comparable circumstances; permanent establishments must be taxed no less favorably than domestic enterprises carrying on the same activities (subject to allowances and certain rate distinctions); cross-border payments are deductible on equal terms except where other treaty provisions apply; and enterprises owned or controlled by residents of the other Contracting State must not face more burdensome taxation than similar domestic enterprises. Protections cover only taxes within the Agreement.
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