Non-discrimination: foreign nationals and enterprises protected from more burdensome taxation and related requirements in the other contracting state.

Non-discrimination prohibits subjecting nationals, persons, or enterprises of one Contracting State to taxation or connected requirements in the other State that are different or more burdensome than those applied to comparable nationals or enterprises of that other State. Permanent establishments must be taxed no less favorably than local enterprises carrying on the same activities, with exceptions for personal allowances and specified treaty provisions. Cross-border interest, royalties and similar payments and debts between related enterprises must be deductible under the same conditions as if made to residents, except where specific articles provide otherwise.

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