Non-discrimination ensures taxpayers and permanent establishments receive tax treatment no less favourable than domestic counterparts.

Non-discrimination requires that nationals and other persons not be subjected in the other Contracting State to taxation or connected requirements different or more burdensome than those applied to domestic persons in comparable circumstances; permanent establishments of enterprises must receive no less favourable tax treatment than domestic enterprises conducting the same activities; interest, royalties and similar payments shall be deductible under the same conditions as if paid to a domestic resident except where specific treaty provisions apply; parity also covers enterprises partly or wholly owned or controlled by residents of the other State. The Article covers taxes of every kind.

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