Non-discrimination in tax treaties ensures equal tax treatment for nationals and enterprises across Contracting States without resident-only reliefs. Non-discrimination prohibits differential or more burdensome taxation or connected requirements of nationals or enterprises of one Contracting State in the other Contracting State compared with similarly situated nationals or enterprises; permanent establishments must be taxed no less favourably than domestic enterprises carrying on the same activities. The rule does not obligate a State to grant resident-only personal allowances, reliefs, reductions or deductions, and applies to enterprises whose capital is wholly or partly owned or controlled by residents of the other Contracting State. 'Taxation' refers to taxes covered by the Convention.
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 for nationals and enterprises across Contracting States without resident-only reliefs.
Non-discrimination prohibits differential or more burdensome taxation or connected requirements of nationals or enterprises of one Contracting State in the other Contracting State compared with similarly situated nationals or enterprises; permanent establishments must be taxed no less favourably than domestic enterprises carrying on the same activities. The rule does not obligate a State to grant resident-only personal allowances, reliefs, reductions or deductions, and applies to enterprises whose capital is wholly or partly owned or controlled by residents of the other Contracting State. "Taxation" refers to taxes covered by the Convention.
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