Non-discrimination in tax treatment protects nationals and enterprises from less favourable taxation and preserves equal deductibility across borders.

Article 25 requires non-discrimination in taxation: nationals and enterprises of one Contracting State must not face taxation or related requirements that are other or more burdensome than those applying to nationals or similar enterprises of the other State. Permanent establishments must be taxed no less favourably than comparable domestic enterprises, subject to the substituted provision noted. Resident-only personal allowances need not be extended to non-residents. Payments to residents of the other State are deductible under the same conditions as payments to residents, except where specific treaty provisions apply, and domestic exemptions and reliefs shall not be adversely affected.

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