Non-discrimination

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....jected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States. 2. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State....

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....ed as imposing a legal obligation on a Contracting State to extend to the residents of the other Contracting State the benefit of any treatment preference or privilege which may be accorded to any other State or its residents through agreements to which the first-mentioned Contracting State may be a party. 5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or co....