Non-discrimination in tax treaties prevents more burdensome taxation on foreign nationals and enterprises, including permanent establishments and foreign owned enterprises. Non-discrimination prohibits taxing nationals of one Contracting State in the other State more onerously than that State's own nationals; taxation of a permanent establishment of an enterprise must not be less favourably levied than on domestic enterprises in like circumstances. States need not grant resident only personal allowances or reliefs to non residents. Enterprises partly or wholly owned or controlled by residents of the other Contracting State must not face more burdensome taxation than similar domestic enterprises. 'Taxation' means the taxes covered by 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 in tax treaties prevents more burdensome taxation on foreign nationals and enterprises, including permanent establishments and foreign owned enterprises.
Non-discrimination prohibits taxing nationals of one Contracting State in the other State more onerously than that State's own nationals; taxation of a permanent establishment of an enterprise must not be less favourably levied than on domestic enterprises in like circumstances. States need not grant resident only personal allowances or reliefs to non residents. Enterprises partly or wholly owned or controlled by residents of the other Contracting State must not face more burdensome taxation than similar domestic enterprises. "Taxation" means the taxes covered by the Agreement.
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