ARTICLE 24

Non-Discrimination

(1) Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith which is other or more burdensome that the taxation and connected requirements to which nationals of that other Contracting State in the same circumstances are or may be subjected.

(2) The taxation of 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 carrying on the same activities.

This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities or any other personal circumstances which it grants to its own residents.

(3) 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 Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of that first-mentioned State carrying on the same activities are or may be subjected.

(4) Except in the cases covered by Article 9, Article 11, paragraph (7), and Article 12, paragraph (6), interest, royalties and other sums paid by an enterprise of a Contracting State to a resident of the other Contracting State shall be deductible, for the purposes of determining the taxable profits of the enterprise, under the same conditions as payments made to a resident of the first-mentioned State. Subject to the provisions of Article 22, paragraph (6), debts owed by an enterprise of a Contracting State to a resident of the other Contracting State shall accordingly be deductible in the determination of the taxable property of the enterprise in the same way as debts owed to a resident of the first-mentioned State.

(5) In this Article the term "taxation" means taxes of every kind and description.