Non-discrimination in taxation prevents more burdensome tax treatment of nationals and enterprises of the other Contracting State.

Non-discrimination prohibits a Contracting State from imposing taxation or connected requirements on nationals of the other State that are other or more burdensome than those applied to its own nationals; this extends to non-residents. Permanent establishments of an enterprise from one State in the other must not be taxed less favourably than domestic enterprises in similar circumstances, subject to treaty-consistent exceptions. States need not grant resident-only personal allowances to non-residents. Enterprises owned or controlled by residents of the other State must not face more burdensome tax treatment than similar domestic enterprises.

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