Non-discrimination prevents more burdensome taxation of foreign nationals and foreign-controlled enterprises than domestic counterparts. Non-discrimination requires that nationals and enterprises of one Contracting State not be subjected in the other Contracting State to taxation or related requirements that are other or more burdensome than those applied to nationals or similar domestic enterprises in the same circumstances. The rule covers permanent establishments, while permitting a State to tax PE profits at a higher rate and not to extend resident-only personal allowances to non-residents. 'Taxation' is limited to taxes covered by the Convention.