Non-discrimination: equal taxation and related requirements for foreign nationals and enterprises to prevent more burdensome treatment.

Article 24 mandates Non-Discrimination: nationals and non-residents of one Contracting State must not face taxation or related requirements in the other State that are other or more burdensome than those applied to comparable domestic nationals; permanent establishments must be taxed no less favorably than domestic enterprises; cross-border interest, royalties and similar disbursements are deductible under the same conditions as payments to domestic residents except where other treaty provisions apply; ownership-controlled enterprises must not be taxed more burdenously; the Article covers taxes of every kind.

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