Non-discrimination: equal tax treatment required for foreign nationals and enterprises to prevent discriminatory taxation under the DTAA.

Article 24A imposes a non-discrimination rule requiring that nationals and enterprises of one Contracting State not be subjected in the other State to taxation or connected requirements that are more burdensome than those applied to comparable domestic nationals or enterprises; it requires equivalent treatment for permanent establishments and equal deductibility of interest, royalties and similar payments except where specific DTAA provisions apply, extends protection to controlled enterprises, applies to all taxes, and preserves exceptions for anti-avoidance measures, specified R&D incentives with equal access, and measures agreed by Exchange of Notes.

---

---

---