Non-discrimination in taxation ensures nationals and enterprises receive equal tax treatment to comparable domestic taxpayers. Non-discrimination prohibits more burdensome taxation or connected requirements of nationals or persons in similar circumstances, irrespective of residency, and requires that permanent establishments and enterprises owned or controlled by residents of the other Contracting State receive taxation and deductibility treatment no less favourable than that accorded to comparable domestic enterprises, subject to treaty exceptions and the exclusion of resident-only personal allowances and specified treaty provisions on interest, royalties and related matters.