Article 23 - Non-Discrimination

Non-discrimination in taxation ensures equal tax treatment for foreign nationals and enterprises across treaty states.

Non-discrimination requires that nationals and certain non-resident individuals not be subjected in the other Contracting State to taxation or connected requirements that are different or more burdensome than those applied to that State's own nationals. Permanent establishments must be taxed no less favourably than domestic enterprises carrying on the same activities, and, except where other treaty provisions apply, payments such as interest, royalties and technical service fees paid to residents of the other State are deductible under the same conditions as if paid to a resident.