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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 24

Non-Discrimination in Taxation

(1) Persons with permanent residency or an habitual abode in a Contracting State will not be subjected in the other Contracting State to any taxation, or any requirement connected therewith, which is more burdensome than taxation and associated requirements to which persons with permanent residency or an habitual abode in that other State in the same circumstances are or may be subjected.

This provision must not be construed as obliging a Contracting State to grant to persons with permanent residency or an habitual abode in the other Contracting State any personal allowances, relief or reductions for taxation purposes, which it grants to persons with permanent residency or an habitual abode in the first mentioned State.

(2) Taxation of income and profits that a person with permanent residency or an habitual abode in a Contracting State derives through a permanent establishment in the other Contracting State, or through the capital of such permanent establishment, will not be less favourable in that other State than taxation levied on income, profits, and capital of persons with permanent residency or an habitual abode in the other Contracting State carrying on like activity under the same conditions.

(3) The provisions of this article must not be construed as obliging a Contracting State to grant to persons with permanent residency in the other Contracting State tax allowances that are granted by the first mentioned State to persons with permanent residency in third states by virtue of tax treaties with them.

(4) The provisions of this article shall apply to the taxes that are the subject of the present Convention.