Section 18R | Meaning of “full treaty territory”

(1)For the purposes of this Chapter a territory is a “full treaty territory” if—

(a)double taxation arrangements have been made in relation to the territory, and

(b)the arrangements contain a relevant non-discrimination provision.

(2)“Relevant non-discrimination provision” means a provision to the effect that the taxation on a permanent establishment of an enterprise of a state which is party to the arrangements (a “contracting state”) is not to be less favourably levied in any other contracting state than the taxation levied on enterprises of that other contracting state carrying on the same activities.