Non-discrimination: equal taxation treatment for foreign nationals and enterprises under the DTAA, subject to residency-related allowances exceptions. The Article bars discriminatory taxation: nationals of one Contracting State must not face more burdensome taxation or related requirements in the other State than that applied to its nationals in comparable circumstances. Taxation of a permanent establishment must not be less favourable than for domestic enterprises in similar activities, subject to treaty-consistent rate differences. States are not required to extend residence-only personal allowances to non-residents. Enterprises owned or controlled by residents of the other State must not receive less favourable tax treatment than similar domestic enterprises. 'Taxation' means taxes covered by the Convention.