Article 24 - Non - Discrimination

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..... nd of nationality is forbidden 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 .....

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..... racting 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. 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 resp .....

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..... r the same conditions as if they had been contracted to a resident of the first-mentioned State. [ Para 4 of Article 24 ] Forbids a Contracting State to give less favourable treatment to an enterprise 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 Contractin .....

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..... owns its capital, something that clearly goes beyond the taxation of the resident enterprise alone. Scope of this article This paragraph states that the scope of the Article is not restricted by the provisions of Article 2. The Article therefore applies to taxes of every kind and description levied by, or on behalf of, the State, its political subdivisions or local authorities. .....

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..... d been paid to a resident of the first-mentioned State. 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. [ Para 4 of Article 24 ] .....

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