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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 23

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 or connected obligations to which nationals of that other State are or may be subjected to under the same circumstances. This provision shall, notwithstanding the provisions of Article 1, also apply to individuals who are not residents of one or both of the Contracting States.

(2) Residents 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 or connected obligations to which residents of that other State are or may be  subjected to under the same circumstances.

(3) Taxation levied on a permanent establishment that an enterprise or a resident 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 or residents of the other State carrying on the same activity in that other State.

(4) No provision of this Article shall 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 that it grants to its own residents.

(5) Except where the provisions of Article 9, paragraph (7) of Article 11, or paragraph (6) of Article 12, apply, for the purpose of determining the taxable profits of an enterprise, the interest, royalties and other disbursements paid by an enterprise of a Contracting State 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.

(6) 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.

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