Non-discrimination in taxation prevents differential or more burdensome tax treatment for foreign nationals and enterprises under a tax treaty.

Non-discrimination requires that nationals and enterprises of a Contracting State not be subjected in the other State to taxation or tax-related requirements that are different or more burdensome than those applied to comparable nationals or enterprises of that other State. The rule covers permanent establishments, subject to a reservation on differential rates and Article 7(3), and excludes obligations to grant residency-only personal allowances or to compute shipping profits identically; it also protects enterprises owned or controlled by residents of the other State. The provision applies to all taxes covered by the Convention.

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