ARTICLE 24
Non-Discrimination
(1) Nationals of a Contracting State may not be subjected in the other Contracting State to any taxation or therewith associated obligation which is different from or more burdensome than the taxation and therewith associated obligations to which citizens of the other State are or would be subjected under the same conditions, especially with respect to residence. This provision applies irrespective of Article 1 also to persons who are not resident in either Contracting State.
(2) Stateless persons who are resident in one Contracting State may not be subjected in any Contracting State to any taxation or therewith associated obligation that is different from or more burdensome than the taxation and therewith associated obligation to which the citizens of the State in question are or could be subjected under the same conditions.
(3) The taxation of a permanent establishment, which is maintained by a business of a Contracting State in the other Contracting State, may not be less favourable than the taxation of businesses of the other State that perform the same activity. This provision may not be interpreted as if it obligated a Contracting State to grant people's resident in the other Contracting State tax exemptions, favours and discounts that are only granted to persons who reside there.
(4) To the extent that paragraph (1) of Article 9, paragraph (8) of Article 11 or paragraph (6) of Article 12 do not apply, interest, royalties and other remunerations that a business in a Contracting State pays to a person resident in the other Contracting State, may be deducted from the determination of the taxable profits of this business under the same conditions as payments to a person resident in the former State. Correspondingly, debts that a business of a Contracting State owes to a person resident in the other Contracting State, may be deducted in the determination of the taxable assets of this business under the same conditions as debts owed to a person resident in the former State.
(5) Businesses of a Contracting States whose capital belongs wholly or partly, directly or indirectly, to a person or several persons who are resident in the other Contracting State or is under their control, may not be subjected in the former State to any taxation or connected obligation that is other than or more burdensome than the taxation and connected obligation to which other similar businesses of the former State are or can be subjected.
(6) This Article applies irrespective of the Article 2 to taxes of every kind and designation.