Non-discrimination in taxation ensures foreign nationals and enterprises do not face more burdensome tax treatment than domestic counterparts. Non-discrimination requires nationals of one Contracting State not be subjected in the other State to taxation or connected requirements that are different or more burdensome than those applied to nationals of that other State. Permanent establishments of enterprises must not be taxed less favourably than domestic enterprises, with no obligation to grant resident-only personal allowances. Interest, royalties and debts between cross-border parties are to be deductible under the same conditions as domestic transactions, subject to specific Article exceptions. Enterprises owned or controlled by residents of the other State must not face more burdensome taxation. The provision applies to all taxes.