Non-discrimination prevents cross-border taxpayers facing more burdensome tax treatment, ensuring equal deductibility and enterprise parity.

The Article enacts Non-Discrimination, forbidding taxation or related requirements in one Contracting State that are other or more burdensome than those applied to its own nationals or comparable enterprises, extending to non residents. It requires that taxation of a permanent establishment be no less favourable than for domestic enterprises, that enterprises owned or controlled by residents of the other State not face more burdensome requirements, and that interest, royalties and similar payments be deductible on the same conditions as payments to residents except where specific treaty exceptions apply.

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