Non-discrimination in taxation prevents differential tax treatment of nationals and comparable enterprises across treaty states. Article 26 sets a non-discrimination rule preventing a Contracting State from imposing taxation or related requirements on nationals, permanent establishments, or enterprises controlled by residents of the other State that are different or more burdensome than those applied to comparable domestic persons or enterprises, subject to specified exceptions for personal allowances, non-resident tax provisions, certain non-resident citizen reliefs, and domestic tax concessions; 'taxation' is limited to 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 taxation prevents differential tax treatment of nationals and comparable enterprises across treaty states.
Article 26 sets a non-discrimination rule preventing a Contracting State from imposing taxation or related requirements on nationals, permanent establishments, or enterprises controlled by residents of the other State that are different or more burdensome than those applied to comparable domestic persons or enterprises, subject to specified exceptions for personal allowances, non-resident tax provisions, certain non-resident citizen reliefs, and domestic tax concessions; "taxation" is limited to the taxes covered by the Agreement.
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