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Non-discrimination clause in tax treaties – Select issues and recent developments

April 30, 2019[2019] 104 459 (Article)
Discrimination means unequal treatment in similar and comparable situations. Article 24 of the Model Tax Convention (‘MTC’) deals with Non-discrimination and provides that the tax provision should not provide for differential treatment to the non-residents in similar situations. Hence, Article 24 of the MTC is a special rule providing for avoidance of discrimination against nationals or residents of another contracting state.
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