Non-discrimination in taxation ensures equal tax treatment for nationals, enterprises and permanent establishments across treaty partners. Non-discrimination requires that nationals and persons not be subjected in the other Contracting State to taxation or related requirements that are different or more burdensome than those applied to nationals in comparable circumstances; it extends to non-residents. Enterprises' permanent establishments must be taxed no less favourably than domestic enterprises carrying on the same activities, and enterprises owned or controlled by residents of the other State must not face more burdensome taxation than similar domestic enterprises. Exceptions include personal allowances and specified provisions on interest, royalties and similar payments. The Article applies to the taxes covered by the Agreement.