Non-discrimination principle: equal tax treatment for foreign nationals and enterprises, subject to domestic allowance rules. Non-discrimination requires that nationals of one Contracting State not be subjected in the other Contracting State to taxation or related requirements that are different or more burdensome than those applicable to nationals of that other State in the same circumstances. Enterprises and permanent establishments must not be taxed less favourably than similar domestic enterprises, while domestic personal allowances need not be granted to non residents.