Non-discrimination in international taxation: equal treatment for nationals, stateless persons, permanent establishments and cross-border deductions.

The Article prohibits more burdensome taxation or related requirements on nationals and, where specified, non-residents and stateless persons compared with comparable nationals of the other State; it requires that permanent establishments of enterprises be taxed no less favourably than domestic enterprises, allows parity in deductibility of cross border interest, royalties and other specified disbursements and equal treatment of debts for taxable capital purposes, bars less favourable treatment of enterprises owned or controlled by residents of the other State, and applies to all taxes levied by or on behalf of the State. The UN Model broadens deductible cross border payments to include technical services and automated digital services income.

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