Non-discrimination in taxation: equal tax treatment for foreign nationals and enterprises under the treaty framework. Non-discrimination requires that nationals of one Contracting State not be subject in the other State to taxation or tax-related requirements that are different or more burdensome than those applied to that State's nationals in comparable circumstances; this extends to non-residents. Enterprises' permanent establishments must be taxed no less favourably than local enterprises carrying on the same activities, subject to limited exceptions concerning personal allowances and specified treaty provisions. Deductibility of interest, royalties and similar payments must be on the same conditions as payments to residents except where other treaty provisions apply. Controlled or partly owned enterprises must not face more burdensome taxation than similar domestic enterprises. These obligations apply to taxes covered by the Agreement.