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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

(1) Nationals of a Contracting State shall not be subjected, in the other Contracting State, to any taxation or any connected obligations, which are other than or more burdensome than the taxation and connected obligations to which nationals of that other State are, or may be, subjected to under the same circumstances, especially in terms of residence. Notwithstanding the provisions of Article 1, this provision shall also apply to persons who are not residents of one or both of the Contracting States.

(2) Taxation levied on a permanent establishment that an enterprise of a Contracting State has in the other Contracting State shall not be less favourable in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision may not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, relief and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

(3) Except where the provisions of Article 9, paragraph (7) of Article 11, or paragraph (6) of Article 12 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall be deductible, for the purpose of determination of taxable profits of such enterprise, under the same conditions as if they had been paid to a resident of the first-mentioned State.

(4) 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 connected obligations which are other or more burdensome than the taxation or connected obligations to which other similar enterprises of the first-mentioned State are or may be subjected.

(5) The provisions of this Article, notwithstanding the provisions of Article 2, shall apply to taxes of every kind and description.