Non-discrimination in tax treaties ensures equal tax treatment and deductibility for cross-border nationals and enterprises. Article 25 prohibits more burdensome taxation or related requirements on nationals of one Contracting State in the other State than those applied to that State's own nationals, extends to non-residents, excludes an obligation to grant domestic personal allowances to foreign residents, requires taxation of permanent establishments to be no less favourable than for similar domestic enterprises (subject to exceptions), mandates equal deductibility for cross-border interest, royalties and technical service fees except where other provisions apply, and bars discriminatory treatment of enterprises owned or controlled by residents of the other State.
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 tax treatment and deductibility for cross-border nationals and enterprises.
Article 25 prohibits more burdensome taxation or related requirements on nationals of one Contracting State in the other State than those applied to that State's own nationals, extends to non-residents, excludes an obligation to grant domestic personal allowances to foreign residents, requires taxation of permanent establishments to be no less favourable than for similar domestic enterprises (subject to exceptions), mandates equal deductibility for cross-border interest, royalties and technical service fees except where other provisions apply, and bars discriminatory treatment of enterprises owned or controlled by residents of the other State.
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