Non-discrimination ensures nationals and enterprises receive equal tax treatment and deduction rights under the DTAA.

Non-discrimination requires that nationals and other persons of one Contracting State not face taxation or related requirements in the other State that are other or more burdensome than those applicable to that State's nationals in similar circumstances. Taxation of a permanent establishment must not be less favourably levied than on domestic enterprises conducting the same activities, with no obligation to extend personal allowances for civil status or family responsibilities to non-residents. Payments such as interest and royalties are deductible under the same conditions as if paid to domestic residents, subject to specified Article exceptions, and enterprises with foreign ownership must not face discriminatory taxation.

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