Non-discrimination in taxation: equal treatment for foreign nationals and enterprises, with specified resident relief exceptions. Non-discrimination prohibits differential or more burdensome taxation or related requirements on nationals and stateless residents of a Contracting State compared with domestic nationals in like circumstances, while allowing a Contracting State to withhold personal allowances and exceptional repatriation reliefs limited to its residents. Taxation of a permanent establishment must be no less favourable than for domestic enterprises, cross-border interest, royalties and debts are deductible on the same conditions as domestic equivalents (subject to specified Article exceptions), and enterprises owned or controlled by residents of the other State must not face harsher taxation than similar domestic enterprises.