Non-discrimination prevents more burdensome taxation of foreign nationals and enterprises in the other Contracting State under a tax treaty.

Non-discrimination mandates that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or related requirements that are different or more burdensome than those applied to comparable nationals or enterprises; this protection covers permanent establishments and enterprises with foreign ownership while preserving exceptions for personal allowances, domestic non-resident tax rules, and specified tax concessions. Taxation is confined to taxes covered by the Convention.

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