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of <h1>Equal Tax Treatment for Foreign Nationals and Enterprises Under Bilateral Agreement: Fairness in Deductions and Establishment Rules</h1> Nationals of one Contracting State should not face more burdensome taxation in the other Contracting State than the nationals of that other State in similar circumstances. This applies even to non-residents of either State. Taxation on a permanent establishment of an enterprise should not be less favorable than that on local enterprises. Interest, royalties, and fees paid by an enterprise to a resident of the other State should be deductible under the same conditions as payments to local residents. Companies owned by residents of the other State should not face more burdensome taxation than similar local companies. 'Taxation' refers to taxes covered by the Agreement.
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