Non-discrimination in tax treaties ensures equal tax treatment for foreign nationals and enterprises, subject to specified exceptions.

Non-discrimination prohibits taxing nationals, persons, or enterprises of one Contracting State in the other State on terms more burdensome than those applied to the other State's nationals or similar enterprises, including enterprises with foreign ownership. Permanent establishments of foreign enterprises must receive not less favourable taxation than domestic counterparts, subject to treaty carve-outs. Personal allowances and third-State preferences need not be extended to foreign residents. Interest, royalties and debts between cross-border related parties are to be deductible or treated for taxable capital on the same conditions as domestic equivalents, except where specific treaty provisions apply.

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