Non-discrimination protects nationals and enterprises from more burdensome taxation or related requirements in the other Contracting State.

Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or related requirements that are other or more burdensome than those imposed on that State's nationals or similar enterprises in the same circumstances; enterprises with capital owned or controlled by residents of the other State receive the same protections; the provision does not compel a State to grant resident-only personal allowances to non-residents, and "taxation" means the taxes covered by the Agreement.

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