Abstract
This chapter provides an overview of the non-discrimination obligations in the multilateral General Agreement on Trade in Services (GATS), including national treatment and most favoured nation treatment and examines how the GATS non-discrimination obligations interrelate with the Organization for Economic Co-operation and Development (OECD) and UN Model Tax Treaties. The purpose of the discussion in this chapter is twofold. The first is to make plain the differences in non-discrimination principles that emerge in tax and trade agreements as they apply to non-resident services and service providers. The second is to illustrate the permitted differences in the tax treatment of non-resident service providers under the GATS due to the carve out of tax measures from trade obligations.
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