Non-discrimination in taxation prohibits more burdensome tax treatment of nationals and enterprises of one Contracting State in the other. Non-discrimination requires that nationals of a Contracting State not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to nationals of that other State; this includes non-residents. Permanent establishments of an enterprise must not be taxed less favourably than similar domestic enterprises, subject to the allowance for higher rates on profits of a foreign company's permanent establishment and Article 7 paragraph 3. The Article extends parity to enterprises owned or controlled by residents of the other State and applies to 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 in taxation prohibits more burdensome tax treatment of nationals and enterprises of one Contracting State in the other.
Non-discrimination requires that nationals of a Contracting State not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to nationals of that other State; this includes non-residents. Permanent establishments of an enterprise must not be taxed less favourably than similar domestic enterprises, subject to the allowance for higher rates on profits of a foreign company's permanent establishment and Article 7 paragraph 3. The Article extends parity to enterprises owned or controlled by residents of the other State and applies to taxes of every kind.
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