Non-discrimination in tax treaties bars less favourable taxation and connected requirements for nationals, PEs, cross-border payments. Non-discrimination requires that persons and enterprises of one Contracting State not be subjected in the other State to taxation or related requirements ... Summary
Non-discrimination in tax treaties bars less favourable taxation and connected requirements for nationals, PEs, cross-border payments.
Non-discrimination requires that persons and enterprises of one Contracting State not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to comparable nationals or enterprises; this protection covers non-residents, permanent establishments (subject to business profits rules), deductibility of cross-border interest, royalties and similar payments on equal conditions except where specified treaty provisions apply, and parity for enterprises owned or controlled by residents of the other State.
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