Non-discrimination ensures nationals and enterprises receive taxation treatment no less favourable than domestic counterparts under the DTAA.

Non-discrimination prevents nationals and comparable persons from being subjected in the other Contracting State to taxation or tax-related requirements more burdensome than those applied to that State's own nationals; this extends to non-residents. Permanent establishment taxation must not be less favourably levied on foreign enterprises carrying on the same activities, subject to specified exceptions. Cross-border interest, royalties and debts are deductible under the same conditions as if paid to or contracted with residents, except where other Article provisions apply. Enterprises owned or controlled by residents of the other State shall not face more burdensome taxation or requirements than similar domestic enterprises.

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