Article 24 - Non-discrimination

Non-discrimination principle: equal tax treatment for foreign nationals and enterprises, including deductibility of cross-border payments.

Non-discrimination requires nationals and enterprises of one Contracting State not be subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to nationals or enterprises of that State in comparable circumstances. Permanent establishments must receive taxation no less favourable than domestic enterprises. Cross-border interest, royalties and debts are, subject to stated exceptions, deductible under the same conditions as if paid to residents. Enterprises owned or controlled by residents of the other State must not face more burdensome taxation than similar domestic enterprises. 'Taxation' means the taxes covered by the Convention.