Non-discrimination: equal tax treatment of foreign nationals and enterprises to prevent more burdensome taxation. Non-discrimination mandates that nationals and enterprises of one Contracting State shall not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applying to nationals or similar enterprises of that other State; permanent establishments must be taxed no less favourably, subject to specified exceptions. Payments such as interest and royalties and debts to residents of the other State are deductible under the same conditions as if between residents, and the provision covers taxes of every kind.
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: equal tax treatment of foreign nationals and enterprises to prevent more burdensome taxation.
Non-discrimination mandates that nationals and enterprises of one Contracting State shall not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applying to nationals or similar enterprises of that other State; permanent establishments must be taxed no less favourably, subject to specified exceptions. Payments such as interest and royalties and debts to residents of the other State are deductible under the same conditions as if between residents, and the provision covers taxes of every kind.
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