Non-discrimination in taxation protects foreign nationals and enterprises from less favourable tax treatment under tax treaties.

Non-discrimination requires that nationals of one Contracting State not be subject in the other State to taxation or connected requirements that are different or more burdensome than those applied to that State's own nationals in the same circumstances; taxation of a permanent establishment must not be less favourable than taxation of local enterprises carrying on the same activities under similar circumstances; States may limit personal allowances and enterprises owned or controlled by residents of the other State must not face more onerous taxation than comparable domestic enterprises.

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