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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 any connected obligations therewith, which is other than or more burdensome than the taxation to which the national of that State in the same circumstances, in particular with respect to residence, are or may be subjected. Notwithstanding the provisions of Article 1 of this Convention, this provision shall also apply to persons who are not residents of one or both of the Contracting States.

(2) The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favorable 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 deductions, reliefs and reductions for taxation purposes, on account of civil status or family responsibilities which grants to its own residents.

(3) Except where the provisions of paragraph (1) of Article 9, paragraph (7) of Article 11 in at paragraph 6 of Article 12, paragraph (6) of Article 13 or paragraph (3) of Article 23 of his Convention apply, interest, royalties, income earned as a result of the provision of technical services and other amounts paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purposes of determining the taxable profits of such enterprise, be deducted, 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 any connected obligation therewith, which is other than or more burdensome than the taxation than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected.

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