Non-discrimination protects foreign nationals and enterprises from less favourable taxation and related requirements under the DTAA. Non-discrimination prohibits differential taxation or connected requirements between nationals of the Contracting States in comparable circumstances; permanent establishments must not be taxed less favourably than local enterprises carrying on the same activities; resident-only personal allowances need not be granted to non-residents; enterprises with capital owned or controlled by residents of the other State must not be subjected to more burdensome taxation than similar domestic enterprises; 'taxation' refers 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 protects foreign nationals and enterprises from less favourable taxation and related requirements under the DTAA.
Non-discrimination prohibits differential taxation or connected requirements between nationals of the Contracting States in comparable circumstances; permanent establishments must not be taxed less favourably than local enterprises carrying on the same activities; resident-only personal allowances need not be granted to non-residents; enterprises with capital owned or controlled by residents of the other State must not be subjected to more burdensome taxation than similar domestic enterprises; "taxation" refers to taxes covered by the Convention.
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