Non-discrimination: equal taxation treatment for nationals and permanent establishments across Contracting States. Article 24 forbids discriminatory taxation and connected requirements between nationals and enterprises of the Contracting States, requiring that nationals and permanent establishments of one State be treated no less favourably than comparable nationals or enterprises of the other State; it preserves an exception permitting States to restrict personal allowances to residents and prohibits more burdensome treatment of enterprises owned or controlled by residents of the other State. 'Taxation' refers only to taxes covered by the Convention.
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 taxation treatment for nationals and permanent establishments across Contracting States.
Article 24 forbids discriminatory taxation and connected requirements between nationals and enterprises of the Contracting States, requiring that nationals and permanent establishments of one State be treated no less favourably than comparable nationals or enterprises of the other State; it preserves an exception permitting States to restrict personal allowances to residents and prohibits more burdensome treatment of enterprises owned or controlled by residents of the other State. "Taxation" refers only to taxes covered by the Convention.
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