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.
Stateless persons who are residents of a Contracting State
shall not be subjected in either 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 the State concerned in the same circumstances are or
may be subjected.
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.
Except where the provisions of paragraph 1 of Article 9,
paragraph 7 of Article 11, or paragraph 6 of Article 12 of this
Convention apply and subject to the provisions of paragraph 8 of
Article 11, 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.
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.
Nothing contained in this Article shall be construed as
obliging either Contracting State to grant to individuals not
resident in that State any of the personal allowances, relief and
reductions for tax purposes which are granted to individuals so
resident.
The provisions of this Article shall apply to the taxes which
are the subject of this Convention.
