Non-discrimination in taxation forbids differential tax treatment of foreign nationals and enterprises under the DTAA framework.

Article 24 mandates non-discrimination by prohibiting taxation or tax-connected requirements in one Contracting State that are different or more burdensome for nationals of the other State in like circumstances, extends protection to non-residents, requires no less favourable taxation of permanent establishments of foreign enterprises subject to Article 7(3), allows specified exceptions for higher taxation and movable property prepayment on dividends, denies an obligation to grant resident-only personal allowances to non-residents, and prevents discriminatory treatment of enterprises owned or controlled by residents of the other State; "taxation" means the taxes specified in the Agreement.

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