Non-discrimination clause in tax treaties – Select issues and recent developments – Part 4

In part 3 of the series, I have discussed Article 24(2) which deals with stateless person in detail. In this part, I will discuss Article 24(3) dealing with PE non-discrimination.

This paragraph deals with a ‘permanent establishment’ (PE) that an ‘enterprise of a Contracting State’ has in the other ‘Contracting State’. Thus, it deals with non-discrimination of a resident of a Contracting state in respect of the enterprise carried on through a PE by such person in other contracting state.

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