Non-discrimination in taxation prevents more burdensome tax treatment of foreign nationals and enterprises under tax treaties.

Article 26 bars Contracting States from imposing taxation or related requirements on nationals of the other State that are different or more burdensome than those imposed on their own nationals in comparable circumstances, protects enterprises owned or controlled by residents of the other State from disparate taxation, allows differential taxation of permanent establishments consistent with Article 7(3), and confirms residency-based personal allowances need not be granted to non-residents; taxation means the taxes covered by the Agreement.

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