What is the content of Articel 24 OECD
Article 24 (“NonDiscrimination”) contains the ban on tax discrimination.
Pursuant to paras. 1 and 2, nationals of a Contracting State and stateless persons in the other Contracting State shall not be subjected to any taxation which is other or more burdensome than the taxation to which nationals of that other State in the same circumstances may be subjected.
The taxation of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities (para. 3)
When calculating business profits, payments of interest, royalties and other fees that an enterprise pays to a foreign person must be treated in the same way as they would were these payments made to a national (para. 4).
According to the fourth discrimination ban (para. 5), enterprises of one Contracting State may not be subjected to worse treatment owing to the fact that persons residing in the other Contracting State have a stake in said enterprise
What is defined in the articel 25 of the OECD
If there are difficulties in the application of a DTT, then article 25 sets out an inter‐governmental mutual agreement procedure for the consistent application of DTT.
What is the definition of articel 26 OECD
Article 26 regulates the exchange of information and confidentiality obligations of the Contracting States
What is beneficial for a circum group of people in Articel 27 OECD
Article 27 protects diplomats and consular officers from any restrictions on tax benefits.
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