#### Article 24. Non-discrimination
- 1 Nationals of a Contracting State shall not be subjected in the other Contracting State
to any taxation or any requirement connected therewith, which is other or more burdensome
than the taxation and connected requirements to which nationals of that other State
in the same circumstances, in particular with respect to residence, are or may be
subjected. This provision shall, notwithstanding the provisions of [Article 1](#Verdrag_2_Verdragtekst_1_HoofdstukI_Artikel1), 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 favourably levied in that other
State than the taxation levied on enterprises of that other State carrying on the
same activities.
- 3 Except where the provisions of [paragraph 1 of Article 9](#Verdrag_2_Verdragtekst_1_HoofdstukIII_Artikel9), [paragraph 5 of Article 11](#Verdrag_2_Verdragtekst_1_HoofdstukIII_Artikel11), or [paragraph 5 of Article 12](#Verdrag_2_Verdragtekst_1_HoofdstukIII_Artikel12), apply, interest, royalties and other disbursements paid by an enterprise of a Contracting
State to a resident of the other Contracting State shall, for the purpose of determining
the taxable profits of such enterprise, be deductible 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
requirement connected therewith which is other or more burdensome than the taxation
and connected requirements to which other similar enterprises of the first-mentioned
State are or may be subjected.
- 5 Nothing contained in this Article shall be construed as obliging a Contracting State
to grant to residents of the other Contracting State any personal allowances, reliefs
and reductions for taxation purposes on account of civil status or family responsibilities
which it grants to its own residents.
- 6 Contributions made by or on behalf of an individual who exercises employment or self-employment
in a Contracting State (“the host state”) to a pension fund that is recognised for
tax purposes in the other Contracting State (“the home state”) shall, for the purposes
of:
- a) determining the individual’s tax payable in the host state; and
- b) determining the profits of his employer which may be taxed in the host state;
be treated in the host state in the same way and subject to the same conditions and
limitations as contributions made to a pension fund that is recognised for tax purposes
in that State, to the extent that they are not so treated by the home state.
- 7 Paragraph 6 shall apply only if the following conditions are met:
- a) the individual is subject to the legislation of the home state in accordance with
the [Agreement on Freedom of the Movement of Persons signed on 21 June 1999, between the
Swiss Confederation on one side and the European Community and its Member States on
the other side](/BWBV0001500?labelid=10002430124); and
- b) the individual was not a resident of the host state, and was participating in the
pension fund (or in another similar pension fund for which the first-mentioned pension
fund was substituted), immediately before he began to exercise employment or self-employment
in the host state; and
- c) the pension fund is accepted by the competent authority of the host state as generally
corresponding to a pension fund recognised as such for tax purposes with respect to
individuals by that State.
- 8 The provisions of paragraph 6 and 7 shall apply accordingly to contributions to Dutch
pension (insurance) schemes, which include arrangements with an insurance company
in which an individual participates in order to secure pension or retirement benefits.
- 9 The provisions of this Article shall, notwithstanding the provisions of [Article 2](#Verdrag_2_Verdragtekst_1_HoofdstukI_Artikel2), apply to taxes of every kind and description.