(1) Citizens of a contracting state may not be subject in the other contracting states to any taxes or obligation related to such taxes other than the taxes or tax obligations to which citizens of such other state are subject or may under the same circumstances be subject. Citizens may neither be subject to more burdensome taxes or tax obligations.
(2) The term "citizens" shall denote:
- (a) all citizens who hold citizenship of a contracting state.
- (b) all legally authorized persons in a contracting state.
(3) A permanent installation - which is owned by a project related to a contracting state in another contracting state is not subject to more burdensome taxes that are levied in such other state than the taxes levied on the projects of such other state and which practise the same activity. Such provision may not be interpreted as obligating a contracting state to give residents in the other contracting state any deductions, exemptions or personal discounts as regards taxes in the same manner which the state gives to its citizens as a result of the civil status or family obligations.
(4) Projects of a contracting state whose capital is owned in full or in part or controlled either directly or indirectly by persons residing in the other contracting state are not subject to any taxes or any obligations related to such taxes other than the taxes or tax obligations to which other similar projects in the said state are subject or may be subject and which are more burdensome.