ARTICLE 25
Non-Discrimination
(1) The 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 than the taxation and connected requirements to which nationals of that other State in the same circumstances are or may be subjected.
(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 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) Except where the provisions of Article 9, paragraph (7) of Article 11, or paragraph (5) of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State.
Similarly, any debts of an enterprise of a Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be deductible as if they had been contracted to a resident of the first-mentioned State.
(4) Enterprises of a Contracting State, the capital of which 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 are or may be subjected.
(5) Nothing in this Article shall be construed as affecting:
- (a) the application in the Arab Republic of Egypt of Article 4 paragraph (9) and Article 120 paragraph (4) of the Law 157 of 1981 (as they may be amended from time to time in minor respects without affecting the general principal thereof);
- (b) the application in the Federal Republic of Germany of paragraph (3) of Article 50 of the Income Tax Law and paragraph (3) of Article 23 of the Corporation Tax Law as well as the exemptions conferred in the Federal Republic of Germany by Article 102 of the Valuation Law.
(6) The provisions of this Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind and description.