Article 26 - Non-discrimination

Non-discrimination in taxation ensures equal tax treatment and deductibility for foreign nationals and enterprises.

Non-discrimination prohibits a Contracting State from subjecting nationals or enterprises of the other State to taxation or related requirements that are different or more burdensome than those applied to its own nationals or similar domestic enterprises. Permanent establishments must receive tax treatment no less favourable than domestic counterparts. Enterprises partly or wholly owned or controlled by residents of the other State must not be taxed less favourably than similar domestic enterprises. Interest, royalties and debts between associated residents are deductible under the same conditions as if between domestic residents, subject to specified treaty exceptions.