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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 25

Non-Discrimination

(1) Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or related obligations, which is 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. Notwithstanding the provisions of Article 1 of this Convention, this provision shall also apply to individuals who are not residents of one or both of the Contracting States.

(2) Stateless persons who are residents of a Contracting State shall not be subjected, in the other Contracting State, to any taxation or related obligations, which is other than or more burdensome than the taxation and related obligations to which nationals of the concerned State, in the same circumstances, are or may be subjected.

(3) Taxation levied on a permanent establishment or a fixed base, which 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 shall 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 that it grants to its own residents.

(4) Except where the provisions of Article 9, paragraph (4) of Article 13, or paragraph (4) of Article 14, 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.

(5) 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 and connected obligations to which other similar enterprises of that first-mentioned State are or may be subjected.

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