Non-discrimination in taxation: ensures equal tax treatment for nationals and enterprises across contracting states without residency disadvantage. Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to that State's own nationals in comparable circumstances; this protection extends to certain non-residents. Permanent establishments of enterprises must receive no less favourable tax treatment than domestic enterprises in similar activities. Interest, royalties and similar payments are deductible on the same conditions as if paid to a resident, subject to limited exceptions. The provision also prevents adverse taxation of enterprises owned or controlled by residents of the other State and applies to 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 taxation: ensures equal tax treatment for nationals and enterprises across contracting states without residency disadvantage.
Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to that State's own nationals in comparable circumstances; this protection extends to certain non-residents. Permanent establishments of enterprises must receive no less favourable tax treatment than domestic enterprises in similar activities. Interest, royalties and similar payments are deductible on the same conditions as if paid to a resident, subject to limited exceptions. The provision also prevents adverse taxation of enterprises owned or controlled by residents of the other State and applies to taxes covered by the Agreement.
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