Non-discrimination: equal tax treatment for nationals, enterprises and permanent establishments to prevent burdensome taxation.

Non-discrimination: nationals and persons (including non-residents) must not face taxation or related requirements in the other Contracting State that are different or more burdensome than those applied to that State's nationals; permanent establishments and enterprises with foreign ownership must receive no less favourable tax treatment than comparable domestic enterprises; interest, royalties and similar payments and debts between residents are deductible on the same conditions as if paid to domestic recipients, subject to specific exceptions, and the Article covers taxes of every kind and description.

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