ARTICLE 24
Non-Discrimination
(1) The nationals of a Contracting State shall not be subjected to any taxation or obligation connected therewith in the other Contracting State, which is other or more burdensome than the taxation or obligation which are or could be subjected to the nationals of that other State in the same circumstances. This provision shall also apply to all bodies corporate, partnerships, and other associations that are established according to the laws of either of the Contracting States.
(2) The taxation of a permanent establishment where an enterprise of a Contracting State has in the other Contracting State is not to be levied in this other State in a less favourable manner than the taxation of the enterprises in this other State, which does the same activities. This provision shall not be interpreted as obliging a Contracting State to grant to the residents of the other Contracting State personal reliefs, allowances, and reductions for taxation purposes which it grants only to the residents in its own territory.
(3) Except where the provisions of Article 9, Article 11 paragraph (5) or Article 12 paragraph (6), interest, royalty 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, the debts of an enterprise of a Contracting State relating to residents of the other Contracting State shall, for the purposes of determining the taxable capital of such enterprise, be deductible under the same conditions as if they had been incurred in relation to a resident of the first-mentioned State.
(4) The 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 any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected.