Non-discrimination principle bars cross-border taxation more burdensome than domestic taxation for comparable taxpayers under the treaty.

The Article imposes a non-discrimination obligation preventing more burdensome taxation of nationals or enterprises of one Contracting State in the other State compared with domestic counterparts. It requires parity in taxation of permanent establishments and of enterprises owned or controlled by residents of the other State, while preserving exceptions and excluding an obligation to grant resident-only personal tax allowances. "Taxation" is limited to taxes under the Agreement, and, save for specified exceptions, cross-border interest, royalties and debts are deductible on the same conditions as if between residents.

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