Non-discrimination in taxation: ensure nationals and foreign-controlled enterprises receive no more burdensome tax treatment than domestic counterparts. Non-discrimination ensures nationals of one Contracting State are not subjected in the other State to taxation or related requirements that are different or more burdensome than those applied to that State's own nationals; it extends to taxation of permanent establishments and to enterprises whose capital is owned or controlled by residents of the other State, while preserving resident-only personal allowances and allowing either State to limit tax incentives to its nationals.