DT6923 - DT: Falkland Islands: double taxation agreement, Article 25: Non-discrimination

(1) The taxation on a permanent establishment which an enterprise of a territory has in the other territory shall not be less favourably levied in that other territory than the taxation levied on enterprises of that other territory carrying on the same activities.

(2) Except where the provisions of sub-paragraph (1) of Paragraph 9, sub-paragraph (4) or (5) of Paragraph 11, sub-paragraph (4) or (5) of Paragraph 12, or sub-paragraph (3) or (4) of Paragraph 22 of this Arrangement apply, interest, royalties or other disbursements paid by an enterprise of a territory to a resident of the other territory shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned territory.

(3) Enterprises of a territory, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other territory shall not be subjected in the first-mentioned territory 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 territory are or may be subjected.

(4) Nothing contained in this Paragraph shall be construed as obliging either territory to grant to individuals not resident in that territory any of the personal allowances, reliefs and reductions for tax purposes, which are granted to individuals so resident.

(5) The provision of this Paragraph shall apply to the taxes which are the subject of this Arrangement.