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of <h1>Non-discrimination in taxation: equal treatment for nationals, permanent establishments, and related payments and allowances (Article 24)</h1> Nationals and persons of a Contracting State shall not be subjected in the other Contracting State to taxation or related requirements more burdensome than those applied to its own nationals or similar residents; permanent establishments of an enterprise must not be taxed less favorably than domestic enterprises, subject to specified exceptions; personal allowances, family-based reliefs and benefits accorded to a State's own residents need not be extended to residents of the other State; preferential treatment granted under third-party agreements need not be extended; enterprises partly or wholly owned or controlled by residents of the other State must not face more burdensome taxation than similar domestic enterprises; interest, royalties and similar payments are deductible on the same terms as if paid to residents, except where other treaty provisions apply; non-taxation of nationals' shares under a State's law is not discrimination; 'taxation' means the taxes covered by the Agreement.
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