Non-discrimination in taxation ensures equal tax treatment for nationals and enterprises across contracting states. Non-discrimination bars a Contracting State from imposing taxation or related requirements on nationals or enterprises of the other State that are other or more burdensome than those applied to its own nationals or similar enterprises; permanent establishments must not be taxed less favourably than comparable domestic enterprises subject to specified exceptions; cross-border payments and debts to residents of the other State must be deductible under the same conditions as domestic equivalents; the rule applies to all taxes.
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 ensures equal tax treatment for nationals and enterprises across contracting states.
Non-discrimination bars a Contracting State from imposing taxation or related requirements on nationals or enterprises of the other State that are other or more burdensome than those applied to its own nationals or similar enterprises; permanent establishments must not be taxed less favourably than comparable domestic enterprises subject to specified exceptions; cross-border payments and debts to residents of the other State must be deductible under the same conditions as domestic equivalents; the rule applies to all taxes.
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