ARTICLE 25
Non-Discrimination
(1) Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other 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.
(2) Taxation on a permanent establishment that an enterprise of a Contracting State has in the other Contracting State shall not be less favourable than the imposition of the companies of this other State, which carries on the same activity.
This provision shall not be construed as obliging a Contracting State to grant to the residents of the other Contracting State personal deductions, abatements and tax reductions on account of civil status or family responsibilities which it grants to its own residents.
(3) 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 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.
(4) The term "taxation" indicates in this Article, the taxes of every kind and description.