Non-discrimination in tax treaties prevents more burdensome taxation of foreign nationals and enterprises compared to domestic counterparts. Article 25 prohibits discriminatory taxation by requiring that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to its own nationals or similar enterprises. It preserves resident-only personal allowances, defines the scope of covered taxes, ensures equal treatment for permanent establishments and controlled enterprises, and mandates that cross-border interest, royalties and debts be deductible on the same terms as domestic transactions, while safeguarding domestic exemptions and subjecting certain payments to other Article-specific exceptions.
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 of foreign nationals and enterprises compared to domestic counterparts.
Article 25 prohibits discriminatory taxation by requiring that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to its own nationals or similar enterprises. It preserves resident-only personal allowances, defines the scope of covered taxes, ensures equal treatment for permanent establishments and controlled enterprises, and mandates that cross-border interest, royalties and debts be deductible on the same terms as domestic transactions, while safeguarding domestic exemptions and subjecting certain payments to other Article-specific exceptions.
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