Non-Discrimination: prohibits disparate taxation or connected requirements against nationals or enterprises of the other Contracting State.

Article 21 prohibits discriminatory taxation by requiring that nationals of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to that State's nationals. "National" includes individuals and legal persons, partnerships and associations constituted under a Contracting State's law. The Article also requires equal taxation of permanent establishments and prevents less favourable treatment of enterprises partly or wholly owned or controlled by residents of the other Contracting State, while not obliging extension of personal allowances tied to civil status or family responsibilities.

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