Non-discrimination: ensures taxpayers and permanent establishments receive equal tax treatment and deduction rights under the tax treaty. Non-discrimination requires nationals and certain non-residents not be subjected to taxation or related requirements that are different or more burdensome than applied to comparable nationals; permanent establishments and enterprises with cross-border ownership must receive no less favorable taxation than similar domestic enterprises; cross-border interest, royalties and similar payments are deductible under the same conditions as if paid to domestic residents, subject to specified treaty exceptions; the Article applies to taxes covered by the Agreement.