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Non-discrimination in taxation prevents foreign nationals and enterprises from facing more burdensome tax treatment. Non-discrimination bars a Contracting State from imposing taxation or related requirements on nationals of the other State that are different or more burdensome than those imposed on its own nationals in similar circumstances, and this protection extends to non-residents. Permanent establishment taxation must be no less favorable than for domestic enterprises, though personal allowances may be reserved. Interest, royalties and debts to residents of the other State must be deductible or treated on the same terms as if to domestic residents, and enterprises owned or controlled by residents of the other State must not face more burdensome taxation. The Article covers taxes of every kind.
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Provisions expressly mentioned in the judgment/order text.
Non-discrimination in taxation prevents foreign nationals and enterprises from facing more burdensome tax treatment.
Non-discrimination bars a Contracting State from imposing taxation or related requirements on nationals of the other State that are different or more burdensome than those imposed on its own nationals in similar circumstances, and this protection extends to non-residents. Permanent establishment taxation must be no less favorable than for domestic enterprises, though personal allowances may be reserved. Interest, royalties and debts to residents of the other State must be deductible or treated on the same terms as if to domestic residents, and enterprises owned or controlled by residents of the other State must not face more burdensome taxation. The Article covers taxes of every kind.
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