CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF AUSTRIA AND THE GOVERNMENT OF THE REPUBLIC OF MOLDOVA

CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF AUSTRIA AND THE GOVERNMENT OF THE REPUBLIC OF MOLDOVA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION

CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF AUSTRIA AND THE GOVERNMENT OF THE REPUBLIC OF MOLDOVA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON PROPERTY


Inkraft seit 2005-01-01

Artikel 23
NON-DISCRIMINATION

1. 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, in particular with respect to residence, are or may be subjected.  


2. Stateless persons who are residents of a Contracting State shall not be subjected in  either 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 the State concerned in the same circumstances, in particular with respect to residence,  are or may be subjected. 


3. 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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for  taxation purposes on account of civil status or family responsibilities which it grants to its  own residents. 


4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or  paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an  enterprise of a Contracting State to a resident of the other Contracting State 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 State. Similarly, any  debts of an enterprise of a Contracting State to a resident of the other Contracting State  shall, for the purpose of determining the taxable property of such enterprise, be deductible  under the same conditions as if they had been contracted to a resident of the  first-mentioned State.


5. 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 the first-mentioned State are or may be  subjected.