Non-discrimination ensures equal tax treatment under a tax treaty, preventing more burdensome taxation on foreign nationals and enterprises. Article 24 prohibits discriminatory taxation under the DTAA by requiring 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; it defines taxation as the taxes covered by the Agreement. The Article further requires that permanent establishments of an enterprise from one Contracting State be taxed no less favourably than domestic enterprises carrying on like activities, preserves resident-only personal allowances, and mandates that interest, royalties and similar payments to residents of the other State be deductible under the same conditions as if paid to residents, subject to specified exceptions.
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 ensures equal tax treatment under a tax treaty, preventing more burdensome taxation on foreign nationals and enterprises.
Article 24 prohibits discriminatory taxation under the DTAA by requiring 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; it defines taxation as the taxes covered by the Agreement. The Article further requires that permanent establishments of an enterprise from one Contracting State be taxed no less favourably than domestic enterprises carrying on like activities, preserves resident-only personal allowances, and mandates that interest, royalties and similar payments to residents of the other State be deductible under the same conditions as if paid to residents, subject to specified exceptions.
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