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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 26

Non-Discrimination

(1) Nationals of a Contracting State shall not be liable in the other Contracting State to any taxation or any connected obligations, that are other than or more burdensome than the taxation and connected obligations, which apply to nationals of that other State, who have the same status, particularly with respect to residence. This provision, notwithstanding the provisions of Article 1 of this Convention, shall also apply to persons who are not residents of one or both of the Contracting States.

(2) The taxation on a permanent establishment, which is owned by an enterprise of a Contracting State in the other Contracting State, shall not be less appropriately levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obligating a Contracting State to grant to residents of the other Contracting State any personal discounts, remission and tax deductions as equivalent to the same granted to its residents on account of their civil status or family responsibilities.

(3) Except where the provisions of Paragraph (1) of Article (9), Paragraph (6) of Article (11), or Paragraph (6) of Article (12) of this Convention apply, interest, royalties and other disbursements paid by an establishment of a Contracting State to a resident of the other Contracting State shall, for the purpose of the taxable profits of such establishment, be deductible under the same conditions applying to the deduction of disbursements paid to a resident of the first-mentioned State.

(4) Enterprises of a Contracting State, the capital of which is owned or controlled in whole or in part, directly or indirectly, by one or more residents of the other Contracting State, shall not be subject in the first-mentioned State to any taxation or any connected obligations, which are other than or more burdensome than the taxation to which other similar enterprises of the first-mentioned State are or may be subject to.