Non-discrimination in taxation: foreign nationals and enterprises must not face more burdensome tax treatment than residents. Non-discrimination prohibits a Contracting State from imposing taxation or related requirements on nationals of the other State that are other or more burdensome than those applied to resident nationals in the same circumstances. The rule extends to permanent establishments, requiring no less favourable taxation than domestic enterprises in comparable circumstances. The provision preserves a residency-based exception for personal allowances, and requires equal tax treatment for enterprises partly or wholly owned or controlled by residents of the other Contracting State. 'Taxation' means the taxes covered by the Agreement.