Non-discrimination: equal tax treatment for foreign nationals and enterprises under the tax treaty, including deductibility parity. Non-discrimination requires nationals and persons of one Contracting State not to be subjected in the other Contracting State to taxation or connected requirements that are other or more burdensome than those applied to nationals of that other State in comparable circumstances, including with respect to residence, and extends to persons who are not residents. The rule also protects permanent establishments, ensures parity in deductibility of interest, royalties and debts between related residents, safeguards enterprises owned or controlled by non-resident nationals, and applies to taxes of every kind and description.