Non-discrimination in taxation: equal tax treatment for foreign nationals, permanent establishments, and related cross-border payments.

Non-discrimination mandates that nationals of one Contracting State not face more burdensome taxation or tax-related requirements in the other State than that State's nationals in comparable circumstances, extending to non-residents. Permanent establishments of enterprises must be taxed no less favorably than domestic enterprises carrying on the same activities, with limited exceptions for personal allowances and specified articles. Cross-border interest, royalties and similar payments are deductible on the same terms as payments to residents except as otherwise provided, and enterprises owned or controlled by residents of the other State must not be subjected to more burdensome taxation than similar domestic enterprises. Protections apply only to taxes covered by the Agreement.

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