ARTICLE 23

Non-Discrimination

(1) Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or requirement connected therewith, which is other than 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, especially in terms of residence. This provision shall, notwithstanding the provisions of Article 1, 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 to any taxation or connected requirements in either of the Contracting States, which is other or more burdensome than the taxation and connected requirements to which the nationals of the concerned State in the same circumstances are or may be subjected.

(3) Taxation of a permanent establishment that an enterprise of a Contracting State has in the other Contracting State shall not be less favorably 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 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 (6) of Article 12 are applicable, interests, 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. In the same way, the debts of an enterprise of a Contracting State contracted towards a resident of the Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be deductible under the same conditions as if they had been contracted towards a resident of the first-mentioned State.

(5) 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 State to any taxation or requirement connected therewith which is other or more burdensome than that to which other similar enterprises of that first-mentioned State are or may be subjected.

(6) This Article applies notwithstanding the provisions of Article 2 for taxes of every kind and description.