Non-discrimination prohibits less favourable tax treatment of foreign nationals and enterprises under the tax treaty.

Non-discrimination prohibits subjecting nationals and other persons in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to that State's own nationals in similar circumstances, and this protection applies to taxes of every kind. Permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities, subject to reservations on personal allowances, and cross-border payments such as interest and royalties are deductible under the same conditions unless specific treaty provisions provide otherwise.

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