Non-discrimination protects taxpayers from more burdensome cross-border taxation under the DTAA and ensures equal tax treatment.

Non-discrimination under the DTAA prohibits differential or more burdensome taxation and related requirements on nationals and enterprises of one Contracting State in the other State, extends to persons irrespective of residence, requires equal taxation treatment of permanent establishments and similarly owned enterprises, and mandates that cross-border interest, royalties and other disbursements be deductible on the same conditions as domestic payments, subject to specified treaty exceptions; the provision applies to all taxes covered by the Convention.

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