Non-discrimination protects cross-border taxpayers from discriminatory taxation and unequal treatment of permanent establishments and payments.

Non-discrimination prevents nationals of one Contracting State from facing taxation or related requirements in the other State that are other or more burdensome than those applied to that State's own nationals in like circumstances, including nonresidents. Permanent establishments must receive no less favourable taxation than domestic enterprises carrying on the same activities, subject to specified exceptions. Cross-border payments such as interest and royalties, debts and capital, and enterprises owned or controlled by residents of the other State must be treated on equal conditions. The provision applies to taxes of every kind.

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