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The Non-Discrimination Clause under Bilateral Tax Treaties (Japanese)

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  • MASUI Yoshihiro

Abstract

This paper briefly surveys existing literature on the non-discrimination clause contained in various bilateral tax treaties. Section I gives an overview. Section II reviews the contents of the non-discrimination provision, paying close attention to the text of Article 24 of the OECD Model Tax Convention on Income and on Capital. Certain gaps in the present treaty provision will be revealed. Section III discusses future treaty policy regarding non-discrimination.

Suggested Citation

  • MASUI Yoshihiro, 2010. "The Non-Discrimination Clause under Bilateral Tax Treaties (Japanese)," Discussion Papers (Japanese) 10051, Research Institute of Economy, Trade and Industry (RIETI).
    • Handle: RePEc:eti:rdpsjp:10051
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