Non-discrimination: equal tax treatment for foreign nationals, enterprises, and permanent establishments under the treaty.

Non-discrimination prevents a Contracting State from imposing taxation or related requirements on nationals of the other State that are different or more burdensome than those applied to its own nationals in comparable circumstances, and extends to non-residents. Permanent establishments and enterprises with foreign ownership must not be taxed less favorably or more burdensomely than comparable domestic enterprises. Interest, royalties and similar payments are deductible on the same conditions as if paid to residents, except where specified provisions disapply this rule. The Article applies to taxes covered by the Agreement.

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