ARTICLE 23
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 that which are or may be subjected nationals of that other State in the same state position.
(2) The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State is not established in that other State less favourably than the taxation levied on enterprises of that other State engaged in the same activity.
(3) Enterprises of a Contracting State, the capital of which is wholly or in part, directly or indirectly owned or controlled by one or more residents of the other Contracting State shall not be subjected in the first-mentioned Contracting State to any taxation or any requirement are relative, which is other or more burdensome than that which are or may be subjected to other similar enterprises of that first State.
(4) The term "tax" under this section means, taxes of every kind and description referred to in Article 2 of this Agreement.
(5) These provisions can-not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and tax depending on the status or family responsibilities which it grants to state cuts its own residents.