Non-discrimination in taxation bars more burdensome treatment of foreign nationals and enterprises under bilateral tax treaties.

Non-discrimination prevents nationals and comparable persons from being subjected in the other Contracting State to taxation or connected requirements that are other or more burdensome than those applied to that State's own nationals; this protection also covers non-residents. Permanent establishments and enterprises of one Contracting State must not be taxed less favorably than local enterprises with the same activities, while resident-only personal allowances may be preserved. Interest, royalties and similar payments must be deductible on equal terms except where specified provisions apply, and the Article covers taxes of every kind and description.

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