DT6522 - DT: Egypt: double taxation agreement, Article 23: Non-discrimination
- The nationals of a Contracting State shall not be subjected in
the other Contracting State to any taxation or any requirement
connected therewith which is other or more burdensome than the
taxation and connected requirements to which nationals of that
other State in the same circumstances areor may be subjected.
- The taxation on 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.
- Enterprises of a Contracting State, the capital of which is
wholly or partly owned or controlled, directly or indirectly, by
one or more residents of the other Contracting State, shall not be
subjected in the first-mentioned State to any taxation or any
requirement connected therewith which is other or more burdensome
than the taxation and connected requirements to which other similar
enterprises of that first-mentioned State are or may be subjected.
- Nothing contained in this Article shall be construed as:
- obliging either Contracting State to grant to individuals not
resident in that State any of the personal allowances, reliefs and
reductions for tax purposes which are granted to individuals so
resident;
- affecting the application in Egypt of Articles 5 and 6 of Law
No 14 of 1939 (as they may be amended from time to time in minor
respects without affecting the general principle thereof) provided
that if the exemptions given by either of these Articles are made
available to nationals of any State or territory other than a
Contracting State such exemption shall likewise be made available
to nationals of the United Kingdom;
- affecting the application in Egypt of Article 11 (paragraphs
(1) and (2)) and Article 11 bis of Law No 14 of 1939 (as they may
be amended from time to time in minor respects without affecting
the general principle thereof) provided that if any relief from the
application of those provisions is given to nationals of any State
or territory other than a Contracting State such relief shall
likewise be given to nationals of the United Kingdom.
