ARTICLE 26
Non-discrimination
X. 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 are or may be subjected.
This provision shall apply to persons who are not residents of
one or both of the Contracting States.
2. Except where the provisions of paragraph 3 of Article 7
(Business Profits) apply, the taxation on a permanent
establishment which an enterprise of a Contracting state has in
the other Contracting state shall not be less favorably levied 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, reliefs, and reductions for taxation purposes on
account of civil status or family responsibilities which it
grants to its own residents.
3. Except where the provisions of paragraph 1 of Article 9
(Associated Enterprises), paragraph 7 of Article 11 (Interest),
or paragraph 8 of Article 12 (Royalties and Fees for Included
Services) apply, interest, royalties, and other disbursements
paid by a resident of a Contracting state to a resident of the
other Contracting state shall, for the purposes of determining
the taxable profits of the first-mentioned resident, 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 in this article shall be construed as preventing
either Contracting state from imposing the taxes described in
Article 14 (Permanent Establishment Tax) or the limitations
described in paragraph 3 of Article 7 (Business Profits).