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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 24

Non-Discrimination

(1) Nationals of a Contracting State shall not be subject in the other Contracting State to any taxation or obligation thereon which is other or more burdensome than those to which the nationals of that other State who are in the territory of the other Contracting State who may be in the same situation especially with regard to the residence. This provision shall also apply, notwithstanding the provisions of Article 1, to persons who are not residents of one or both of the Contracting States.

(2) Stateless persons who are residents of a Contracting State shall not be subject in either Contracting State to any taxation or obligation thereon which is other or more burdensome than those to which the nationals of the Contracting State concerned who are in the same situation, particularly with regard to residence.

(3) The taxation on a permanent establishment which a company of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation of the company of that other State carrying on business of the same activity. This provision shall not be construed as obliging a Contracting State to grant residents income taxes on the basis of family circumstances or family responsibilities which it grants to its own residents.

(4) Unless the provisions of paragraph (1) of Article 9, paragraph (7) of Article 11 or paragraph (6) of Article 12 are applicable, interest, royalties and other expenses paid by a company of a Contracting State to a resident of the other Contracting State shall be deductible, for the purpose of determining the taxable profits of that company, under the same conditions as if they had been paid to a resident of the first-mentioned State.

(5) The company of a Contracting State, the capital of which is wholly or partly owned, directly or indirectly, owned or controlled by one or more residents of the other Contracting State, shall not be subject to any taxation or obligation in the first State therein related, which is different or more burdensome than those to which other similar undertakings of the first State are or may be subject.

(6) The provisions of this Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind and description.