ARTICLE 24
Non-Discrimination
(1) Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement relating to the tax which is other or more burdensome than the taxation and liability for such taxes which are or may be subject nationals of that another state they are in the same conditions, particularly with respect to the residence. Notwithstanding the provisions of Article 1, this provision shall also apply to persons who are not residents of one or both Contracting States.
(2) The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall be, in that other Contracting State less favourable than those applicable to enterprises of that other State carrying on the same activities. This provision does not oblige a Contracting State to grant to residents of the other Contracting State any personal allowances, tax relief or tax reduction it grants to its own residents on the basis of marital status or family responsibilities.
(3) Unless they fall within the provisions of paragraph (1) of Article 9, paragraph (7) of Article 11, or paragraph (6) of Article 12, for the purposes of calculating the taxable enrichments of an enterprise of a Contracting State, interest, royalties and other disbursements paid by that company to a resident of the other Contracting State shall be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of the company, in the same conditions as if they had been contracted to a resident of the first State.
(4) Enterprises of a Contracting State, the capital 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, subject to any taxation or any requirement related to any tax which is other or more burdensome than the taxation and related obligations such taxes which are or may be subject other similar enterprises of the first-mentioned State.
(5) The provisions of this article, notwithstanding the provisions of Article apply to taxes of every kind and denominations.