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CHAPTER 1 - General Provisions
CHAPTER 2 - Taxation of Income
CHAPTER 3 - Inheritance Tax
CHAPTER 4 - Registration Fees Other than Inheritance Tax-Stamp Duty
CHAPTER 5 - Administrative Assistance
CHAPTER 6 - Special Provisions
CHAPTER 7 - Transitional Provisions
CHAPTER 8 - Final Provisions
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 37

Non-Discrimination

(1) Nationals of a Member State shall not be subjected in the other Member State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances are or may be subjected.

(2) The taxation on a permanent establishment which an enterprise of a Member State has in one of the other Member State shall not be less favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities.

(3) Enterprises of a Member State, the capital of which is wholly or partly owned or controlled, whether directly or indirectly, by one or more residents of one of the other Member States, shall not be subjected in the first-mentioned Member State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected.

(4) The term "taxation" means, in this Article, taxes of every kind and description referred to in Article 6 of this Regulation.

(5) The provisions of this Regulation shall not preclude the application of more favorable tax provisions provided under the legislation of each of the Member States for the purpose of investments.