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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 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 in the same circumstances, in particular, in terms of residence. This provision shall, notwithstanding the provisions of Article 1, 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 the other State carrying on the same activity in that other State.

(3) Enterprises of a Contracting State whose capital 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 than or more burdensome than the taxation or connected obligations to which other similar enterprises of that first-mentioned State are or may be subjected.

(4) The provision of this Article shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, exemptions and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

(5) The term 'taxation' in the present Article refers to the taxes covered in this Convention.