Non-discrimination in taxation: equal tax treatment for foreign nationals and enterprises to prevent more burdensome measures.

Non-discrimination requires that nationals and non-residents not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to that State's own nationals in comparable circumstances. Permanent establishments must not be taxed less favourably than domestic enterprises carrying on the same activities, subject to exceptions for personal allowances and other specified treaty provisions. Cross-border interest, royalty and similar payments are deductible under the same conditions as if paid to a resident, unless other treaty paragraphs apply.

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