Non-discrimination principles ensure equal tax treatment for cross-border taxpayers and permanent establishments under the treaty.

Nationals of one Contracting State shall not face taxation or related requirements in the other State that are different or more burdensome than those applied to nationals of that other State; this extends to non-residents. Permanent establishments must receive no less favourable tax treatment than domestic enterprises, with specified limitations on personal allowances and statutory differences. Interest, royalties and similar payments to residents of the other State are deductible under the same conditions as if paid to domestic residents, and debts to such residents are similarly treated for capital gains. Enterprises owned or controlled by residents of the other State must not be taxed more harshly than similar domestic enterprises. The Article covers taxes of every kind, subject to treaty exceptions.

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