Non-discrimination: Equal tax treatment required for foreign nationals and enterprises, subject to specified allowances exception.

Nationals of one Contracting State must not face taxation or related requirements in the other State that are different or more burdensome than those applied to that State's own nationals. Taxation of a permanent establishment of an enterprise of one Contracting State in the other State must not be less favourable than taxation of comparable domestic enterprises, subject to specified qualifications. States need not grant personal allowances to residents of the other State, and enterprises owned or controlled by residents of the other State must receive no less favourable taxation or connected requirements than similar domestic enterprises. "Taxation" means the taxes covered by the Agreement.

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