Non-discrimination

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..... y be subjected. This provision shall, notwithstanding the provisions of Article 1, 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 othe .....

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..... nstrued as imposing a legal obligation on a Contracting State to extend to the residents of the other Contracting State the benefit of any treatment preference or privilege which may be accorded to any other State or its residents through agreements to which the first-mentioned Contracting State may be a party. 5. Enterprises of a Contracting State, the capital of which is wholly or partly owned o .....

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..... ilarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. 7. In this Article, the term taxation means taxes which are the subject of this Agreement. - - statute .....

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