of direct taxes include measures taken by a Partner State under its
taxation system which:
(a)
(b)
(c)
(d)
(e)
(f)
apply to non‐resident service suppliers in recognition of the
fact that the tax obligation of non‐residents is determined with
respect to taxable items sourced or located in the territory of
the Partner States;
apply to non‐residents in order to ensure the imposition or
collection of taxes in the territory of the Partner States;
apply to non‐residents or residents in order to prevent the
avoidance or evasion of taxes, including compliance measures;
apply to consumers of services supplied in or from the
territory of another Partner State in order to ensure the
imposition or collection of taxes on such consumers derived
from sources in the territory of the Partner States;
distinguish service suppliers subject to tax on worldwide
taxable items from other service suppliers, in recognition of
the difference in the nature of the tax base between them; or
determine, allocate or apportion income, profit, gain, loss,
deduction or credit of resident citizens, companies or firms or
the branches of the companies or firms, or between related
companies or firms or their branches, in order to safeguard
the tax base of the Partner State.
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