Non-discrimination principle protects nationals and enterprises from more burdensome or differential taxation and connected requirements under the treaty.

The Non-Discrimination provision prohibits a Contracting State from imposing taxation or tax-related requirements that are different or more burdensome on nationals of the other State than on its own nationals in comparable circumstances. It prevents discriminatory treatment of enterprises owned or controlled by residents of the other State, requires comparable taxation of permanent establishments relative to domestic enterprises carrying on the same activities (subject to permitted differences in company profit rates), allows residence-based distinctions, and excludes measures reasonably designed to prevent tax avoidance.

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