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of <h1>Article 26 of Double Tax Agreement: Ensures Non-Discriminatory Taxation Between States, Protecting Nationals and Enterprises Equally.</h1> Article 26 of the Double Tax Avoidance Agreement between two Contracting States prohibits discrimination in taxation. Nationals of one state should not face more burdensome taxation in the other state than its own nationals. This applies to non-residents as well. Taxation on a permanent establishment should not be less favorable than for local enterprises. The article does not require granting personal tax allowances to non-residents. Interest, royalties, and other payments between enterprises of the two states should be deductible under the same conditions as domestic transactions. Enterprises controlled by residents of the other state should not face discriminatory taxation.
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