Non-discrimination in tax treaties ensures equal tax treatment for foreign nationals and enterprises without harsher requirements. Non-discrimination requires 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 nationals or similar enterprises of that other State; this includes equal treatment for permanent establishments, parity in deductibility of interest, royalties and debts (subject to specified exceptions), and protection for enterprises owned or controlled by residents of the other State. The provision covers taxes of every kind and description.
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 foreign nationals and enterprises without harsher requirements.
Non-discrimination requires 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 nationals or similar enterprises of that other State; this includes equal treatment for permanent establishments, parity in deductibility of interest, royalties and debts (subject to specified exceptions), and protection for enterprises owned or controlled by residents of the other State. The provision covers taxes of every kind and description.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
