Non-discrimination prevents discriminatory taxation of nationals and cross-border enterprises, ensuring equal tax treatment and deductions.

Non-discrimination requires that nationals of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to nationals of that other State, extending to non-residents. Permanent establishments must not be less favourably taxed than domestic enterprises; enterprises owned or controlled by residents of the other State must not face more burdensome requirements than similar domestic enterprises; and, except for specified exceptions, interest, royalties and other disbursements paid to residents of the other State are deductible under the same conditions as if paid to residents of the source State.

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