- 20 Marks
IT – Aug 2020 – L1 – Q4- Non-Discrimination
Discuss non-discrimination under Article 24 of MTC regarding nationality, statelessness, PE, deductions, and capital ownership.
Question
Non discrimination
A. Article 24 of the MTC deals with the elimination of tax discrimination in certain precise circumstances. It deals with discrimination on the basis of nationality, statelessness, the permanent establishment of an enterprise, non-residence specifically in relation to the deductibility of certain payments (e.g. interest and royalties), and non-resident direct investors ( share capital) B. Bearer Shares and Bearer Banks
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