Non-discrimination in DTAA: permanent establishments subject to equivalent corporate tax rates where domestic dividend arrangements exist. Taxation of a permanent establishment under the Non-Discrimination article of DTAAs must not be less favourable than taxation of domestic enterprises. Indian law treats a company that makes prescribed arrangements for dividend declaration and payment in India as a domestic company for tax-rate purposes; therefore Finance Act distinctions for 'foreign company' do not, per se, amount to discrimination against a PE. Some DTAAs expressly permit higher rates for PEs, making explicit what is implicit where that sentence is absent.