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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 subjected, in the other Contracting State, to any taxation or connected obligations, which are other than or more burdensome than the taxation or connected obligations to which nationals of that other State are or may be subjected to under the same circumstances. Notwithstanding the provisions of Article 1, this provision shall also apply to persons who are not residents of either one of the Contracting States.

(2) Taxation levied on a permanent establishment that an enterprise of a Contracting State has in the other Contracting State shall not be less favorable in that other State than the taxation levied on enterprises of the other State carrying on the same activity in that other State.

(3) The provisions of this Article shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, exemptions or reductions for taxation purposes on account of civil status or family responsibilities, which it grants to its own residents.

(4) Nothing in this Article shall be construed as obliging a Contracting State to extend to the residents of the other Contracting State benefits or any treatment of a preferential or a privileged nature, which is granted to any other State, or if the residents through the formation of the customs union, economic union, area of commercial preference or through any regional or sub-regional Convention, relating either wholly or partly to taxation, in which the first- mentioned State can be a part of the agreement with any of the Contracting States.

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

(6) In this Article, the term "taxation" means taxes which are the subject of this Convention.