Non-discrimination clause in tax treaties – Select issues and recent developments – Part 2

In part 1 of the series, I have given an overview of Article 24 on Non-discrimination. In this part, I will discuss Article 24(1) which deals with Nationality non-discrimination in detail.

Wordings of the Article 24(1) as per OECD and UN model convention are as under –

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The views in all sections are personal views of the author.