Non-discrimination in taxation requires parity of tax treatment for foreign nationals and enterprises, with limited treaty exceptions.

Non-discrimination obligations prohibit a Contracting State from subjecting nationals or enterprises of the other Contracting State to taxation or related requirements that are more burdensome than those applied to its own nationals or similar domestic enterprises. The rule covers nationals, certain non-residents, permanent establishments, and mandates parity in taxation and in the deductibility of interest, royalties, and other disbursements paid to residents of the other Contracting State, subject to specified exceptions and qualifications.

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