Non-discrimination in taxation prohibits more burdensome tax treatment of nationals and enterprises between treaty states under DTAA.

Non-discrimination bars differential taxation or related requirements based on nationality for individuals and ensures that permanent establishments of an enterprise in the other Contracting State are not taxed less favourably than domestic enterprises carrying on the same activities, while allowing that personal allowances and certain rate differences need not be extended. Interest, royalties and similar payments to residents of the other State are deductible under the same conditions as if paid to residents of the source State, subject to specified treaty exceptions; controlled enterprises must not be subject to more burdensome taxation than similar domestic enterprises.

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