Non-discrimination protections prevent cross-border taxpayers facing more burdensome taxation or requirements than domestic counterparts. Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to nationals or similar enterprises of that other State; this extends to non-residents. Permanent establishments must be taxed no less favourably than domestic enterprises, subject to non-extension of personal allowances for civil or family status. Cross-border interest, royalties, technical fees and similar payments are deductible under the same conditions as payments to domestic residents, except where other Article exceptions apply. The Article covers taxes of every kind and description.
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Provisions expressly mentioned in the judgment/order text.
Non-discrimination protections prevent cross-border taxpayers facing more burdensome taxation or requirements than domestic counterparts.
Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to nationals or similar enterprises of that other State; this extends to non-residents. Permanent establishments must be taxed no less favourably than domestic enterprises, subject to non-extension of personal allowances for civil or family status. Cross-border interest, royalties, technical fees and similar payments are deductible under the same conditions as payments to domestic residents, except where other Article exceptions apply. The Article covers taxes of every kind and description.
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