Article 25A - Non-Discrimination

Non-discrimination protection ensures equal tax treatment for foreign nationals and enterprises under the treaty, subject to specific exceptions.

The Article establishes non-discrimination protections: nationals and non-residents must not be taxed or subjected to connected requirements more burdensomely than nationals in comparable circumstances; permanent establishments must be taxed no less favorably than domestic enterprises carrying on the same activities (subject to allowances and certain rate distinctions); cross-border payments are deductible on equal terms except where other treaty provisions apply; and enterprises owned or controlled by residents of the other Contracting State must not face more burdensome taxation than similar domestic enterprises. Protections cover only taxes within the Agreement.