ARTICLE 24

Non-Discrimination

(1) Nationals of a Contracting State, whether or not the residents 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 one or both of the Contracting States.

(2) Stateless persons who are residents 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 Contracting State are or may be subjected to under the same circumstances.

(3) Taxation levied on a permanent establishment that an enterprise of a Contracting State has in the other Contracting State shall not be less favourable in that other State than the taxation levied on enterprises of the other State carrying on the same activity in that other State. This provision 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) Except where the provisions of paragraph (1) of Article 9, paragraph (5) of Article 11 or paragraph (5) of Article 12, apply, for the purpose of determining the taxable profits of an enterprise, the interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State, shall be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly,   for the purpose of determining the taxable capital of such enterprise, the debts owed by an enterprise of a Contracting State to a resident of the other Contracting State shall be deductible under the same conditions as if they had been contracted with a resident of the first-mentioned State.

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