Common use of NON-DISCRIMINATION Clause in Contracts

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, 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. 6. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, also apply to persons who are not residents of one or both of the Contracting States. (2. ) 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, in particular with respect to residence, are or may be subjected. (3) 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or. (b4) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. (5. ) 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. (6. ) The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, circumstances and under the same conditions are or may 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 Contracting State than the taxation levied on enterprises of that other State carrying on the same activities. 3. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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 Contracting 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 that first-mentioned State are or may be subjectedsubjected in the same circumstances and under the same conditions. 4. Nothing in this Article shall be construed as: (a) obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions which it grants to its own residents; (b) obliging a Contracting State to grant to nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which it grants to its own citizens who are not resident in that Contracting State or to such other persons as may be specified in the taxation laws of that Contracting State. 5. Where a Contracting State grants tax incentives to its nationals designed to promote economic development in accordance with its national policy and criteria, it shall not be construed as discrimination under this Article. 6. The provisions of In this Article shall apply to Article, the term "taxation" means taxes which are the subject of this Agreement.

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, also apply to persons who are not residents of one or both of the Contracting States. (2. ) 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, in particular with respect to residence, are or may be subjected. (3) 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or. (b4) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 5 of Article 11, or paragraph 6 4 of Article 12, 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. Similarly, 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. (5. ) 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. (6. ) The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, 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. 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State it grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. 6. The provisions of Where a Contracting State grants tax incentives to its nationals designed to promote economic or social development in accordance with its national policy and criteria, it shall not be construed as discrimination under this Article shall apply to the taxes which are the subject of this AgreementArticle.

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, also apply ap- ply 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. 3ac- tivities. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. 54. 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 require- ment 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. 65. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

NON-DISCRIMINATION. 1. Nationals The nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, 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, circumstances are or may 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 term "national" means: (a) all individuals possessing the nationality of a Contracting State; (b) all legal persons, partnerships and associations deriving their status as such from the laws in force in a Contracting State. 3. 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. 34. Nothing in this Article shall be construed - (a) as obliging either of the Contracting States, to grant to persons not resident in its territory those personal allowances and reliefs for tax purposes which are by law available only to persons who are so resident; (b) as affecting any provisions of the laws of either Contracting State regarding the imposition of tax on a non-resident person, other than a company; or (c) as affecting any provisions of the laws of either Contracting State regarding the grant of rebate of tax to companies fulfilling specific requirements regarding the declaration and payment of dividends; or (d) as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State it grants to its own nationals who are not residents of resident in that Contracting State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. 6. The provisions of Where a Contracting State grants tax incentives to its nationals designed to promote economic development in accordance with its national policy and criteria, it shall not be construed as discrimination under this Article shall apply to Article. 7. In this Article, the term "taxation" means taxes which are the subject of this Agreement.

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 Contracting 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, also apply to persons who are not residents of one or both of the Contracting States. (2. ) 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 Contracting State concerned in the same circumstances, in particular with respect to residence, are or may be subjected. (3) 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 Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or. (b4) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 9 of Article 11, or paragraph 6 of Article 12, 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 Contracting State. Similarly, 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 Contracting State. (5. ) 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 Contracting 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 Contracting State are or may be subjected. (6. ) The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, also apply to persons who are not residents of one or both of the Contracting States. (2. The ) 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, in particular with respect to residence, are or may be subjected. (3) Subject to the provisions of paragraph 4 of Article 10, 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or. (b4) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. (5. ) 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. 6. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, circumstances are or may 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. ) 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. (3) 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 activitiesactivities in the same circumstances. 3. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a4) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, paragraph 6 of Article 12, or paragraph 6 of Article 1213, apply, interest, royalties and other disbursements or fees for technical services 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-first- mentioned State. (5. ) 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. (6. The provisions ) Nothing contained in the preceding paragraphs of this Article shall apply be construed: a) as obliging either of the Contracting States, to the taxes grant to persons not resident in its territory those personal allowances and reliefs for tax purposes which are by law available only to persons who are so resident; b) as affecting any provisions of the subject law of this AgreementPakistan regarding the imposition of tax on a non-resident person; or c) as affecting any provisions of the law of Pakistan regarding the grant of rebate of tax to companies fulfilling specific requirements regarding the declaration and payment of dividends.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. Stateless persons who are resident of 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

NON-DISCRIMINATION. 1. Nationals The 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, circumstances and under the same conditions are or may 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 other State carrying on the same activitiesactivities in the same circumstances and under the same conditions. 3. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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 of 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 subjectedsubjected in the same circumstances and under the same conditions. 64. The provisions Nothing contained in paragraphs 1, 2 and 3 of this Article shall apply be construed as - (a) obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions which it grants to its own residents; (b) affecting any provisions of the tax laws of the respective Contracting States regarding the imposition of tax on non- resident persons as such; (c) obliging a Contracting State to grant to nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which it grants to its own citizens who are not resident in that State or to such other persons as may be specified in the taxation laws of that State; and (d) affecting any provisions of the tax laws of the respective Contracting States regarding any tax concessions granted to persons fulfilling specified conditions. 5. In this Article the term "taxation" means taxes which are the subject of this Agreement.

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, also apply to persons who are not residents of one or both of the Contracting States. (2. ) 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, in particular with respect to residence, are or may be subjected. (3) 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or. (b4) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 5 of Article 11, or paragraph 6 5 of Article 12, 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. Similarly, 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. (5. ) 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. (6. ) The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, 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 favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals . This provision shall not be construed as preventing a Contracting State from charging the profits of a permanent establishment which a company of the other Contracting State those personal allowances, reliefs and reductions for has in the first mentioned State at a rate of tax purposes which is higher than that imposed on the first-profits of a similar company of the first mentioned Contracting State grants to its own nationals who are not residents State, nor as being in conflict with the provisions of that State or to such other persons as may be specified in the taxation laws paragraph 3 of that StateArticle 7. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, or paragraph 6 of Article 13, apply, interest, royalties royalties, fees for technical services 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. 54. 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. 65. The provisions of this Article shall apply to the taxes which are the subject of covered by this Agreement.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 4 of Article 12, 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. Similarly, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, 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, also shall 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 favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. 3. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 8 7 of Article 1111 (Interest), or paragraph 6 of Article 12, 12 (Royalties) apply, interest, royalties royalties, and other disbursements paid by an enterprise a resident of a Contracting State to a resident of the other Contracting State shall, for the purpose purposes of determining the taxable profits of such enterprisethe first-mentioned resident, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. 54. 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-first- mentioned State are or may be subjected. 65. The provisions of this Article 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. 6. Nothing in this Article shall be construed as preventing a Contracting State from imposing the taxes described in paragraph 4 of Article 10 (Dividends) or subparagraph b) of paragraph 4 of Article 11 (Interest). 7. The provisions of this Article shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply to the taxes which are the subject of this Agreementevery kind and description imposed by a Contracting State or a political subdivision or local authority thereof.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State it grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. 5. 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. 6. Where a Contracting State grants tax incentives to its nationals designed to promote economic or social development in accordance with its national policy and criteria, it shall not be construed as discrimination under this Article. 7. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

NON-DISCRIMINATION. 1. Nationals The nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, 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, circumstances are or may 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 other State carrying on the same activitiesactivities in the same circumstances or under the same conditions. 3. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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 that first-mentioned State are or may be subjected. 64. The provisions of Nothing in this Article shall apply be construed as obliging: (a) a Contracting State to grant to individuals who are resident of the taxes other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; (b) a Contracting State to grant to nationals of the other Contracting State not resident in the first-mentioned State those personal allowances, reliefs and reductions for tax purposes which are by law available on the subject date of signature of this AgreementAgreement only to nationals of the first-mentioned State who are not resident in that State. 5. Nothing in this Article shall be construed so as to prevent either Contracting State from limiting to its nationals the enjoyment of tax incentives designed to promote social or economic development in that State. 6. In this Article, the term "taxation" means taxes to which this Agreement applies.

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 Contracting 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, 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 Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 12 or paragraph 3 of Article 22 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 Contracting State. 54. 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-first- mentioned Contracting 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 Contracting State are or may be subjected. 5. Nothing in this Article shall be construed as preventing either Contracting State from imposing a tax as described in paragraph 6 of Article 7. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description imposed on behalf of a Contracting State or of its political subdivisions or local authorities.

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, 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 favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 12 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. Similarly, 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. 54. 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 Contracting 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. 65. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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 especially with respect to residence, are or may 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 other State carrying on the same activities. 3. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State it grants to its own nationals who are not residents of that State or to such other persons as may be specified in who have been granted such personal allowances, reliefs and reductions under the taxation laws of that StateState as at the date of the signing of this Agreement. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. 5. 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. 6. The provisions of In this Article shall apply to Article, the term “taxation” means taxes which are the subject of this Agreement.

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. 2. This provision shall, notwithstanding the provisions of Article 1, also apply to Stateless persons who are not residents of one a Contracting State shall not be subjected in either Contracting State to any taxation or both any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of the Contracting StatesState concerned in the same circumstances, in particular with respect to residence, are or may be subjected. 23. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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 property of such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. 5. 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. 6. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State it grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, apply, interestinterest (other than interest that has been treated as a dividend under Article 10), 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. 5. 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. 6. Where a Contracting State grants tax incentives to its nationals designed to promote economic or social development in accordance with its national policy and criteria, it shall not be construed as discrimination under this Article. 7. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, also apply to persons who are not residents of one or both of the Contracting States. (2. ) 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, in particular with respect to residence, are or may be subjected. (3) 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or. (b4) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 6 of Article 11, or paragraph 6 4 of Article 12, 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. (5. ) 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. (6. ) The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

NON-DISCRIMINATION. 1. Nationals of a Contracting State territory shall not be subjected in the other Contracting State territory 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 territory in the same circumstances, in particular with respect to residence, are or may 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 Statesterritories. 2. The taxation on a permanent establishment which an enterprise of a Contracting State territory has in the other Contracting State territory shall not be less favourably levied in that other State territory than the taxation levied on enterprises of that other State territory carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging the competent authority of a Contracting State territory to grant to: (a) to residents of the other Contracting State territory any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 7 of Article 12, apply, interest, royalties royalties, and other disbursements paid by an enterprise of a Contracting State territory to a resident of the other Contracting State territory shall, for the purpose purposes 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 Stateterritory. 54. Enterprises of a Contracting Stateterritory, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting Stateterritory, shall not be subjected in the first-mentioned State territory 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 territory are or may be subjected. 65. The provisions of In this Article shall apply to the term “taxation” means taxes which are the subject of this Agreement.

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, 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 Sate 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. (4) Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) individual residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which it grants to its own nationals who are not resident in that Contracting Sate or to such other persons as may be specified in the taxation laws of that Contracting State. (5) Where a Contracting State grants tax incentives exclusively to its nationals designed to promote economic or social developments in accordance with its national policy and criteria, that limitation shall not be construed as discrimination under this Article. (6. ) The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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 therewith that 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, circumstances are or may be subjected. However, a citizen or national of a Contracting State who is not a resident of that Contracting State and a citizen or national of the other Contracting State who is not a resident of the first-mentioned State are not in the same circumstances with respect to the tax of that first-mentioned State. This provision paragraph shall, notwithstanding the provisions provision of Article 11 (General Scope), also apply to persons who are not residents of one or both of the Contracting States. 2. The taxation on a permanent establishment which that an enterprise of a Contracting State has in the other Contracting State shall not be less favourably favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs reliefs, and reductions for tax taxation purposes on account of civil status or family responsibilities which that it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 8 of Article 1111 (Interest), or paragraph 6 of Article 12, 12 (Royalties) apply, interest, royalties royalties, and other disbursements paid by an enterprise a resident of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprisethe first- mentioned resident, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. 5. Enterprises Similarly, any debts of a resident of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of the first-mentioned resident, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State, . 4. Companies that are residents 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 that is other or more burdensome than the taxation and connected requirements to which other similar enterprises companies 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 a tax as described either in paragraph 7 of Article 10 (Dividends) or paragraph 10 of Article 11 (Interest). 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply to taxes of every kind and description imposed by a Contracting State or a political subdivision or local authority thereof, except that in the case of taxes which are not covered by this Convention, the subject provisions of this AgreementArticle shall not apply to any taxation laws of a Contracting State that are in force on the date of signature of this Convention.

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 11 of this Agreement, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs relieves and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. 6. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, 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, circumstances are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, shall also apply to persons who are not residents of one or both of the Contracting States. However, for the purposes of United States tax, and subject to Article 25 (Relief from Double Taxation), a United States national who is not a resident of the United States and a Portuguese national who is not a resident of the United States are not in the same circumstances. 2. The taxation on a permanent establishment which that an enterprise of a Contracting State has in the other Contracting State shall not be less favourably 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 that it grants to its own residents. 3. Nothing in this Article shall be construed as obliging a preventing either Contracting State to grant to: from imposing a tax as described in Article 12 (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that StateBranch Tax). 4. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 8 of Article 1111 (Interest), or paragraph 6 of Article 12, 13 (Royalties) apply, interest, royalties royalties, and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose purposes 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. 5. Enterprises of a Contracting State, the capital 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 that is other or more burdensome than the taxation and connected requirements to which other similar similarly situated enterprises of the first-mentioned State are or may be subjected. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply to the taxes which are the subject of this Agreementevery kind and description imposed by a Contracting State or a political or administrative subdivision or local authority thereof.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, also apply to persons who are not residents of one or both of the Contracting States. (2. ) 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, in particular with respect to residence, are or may be subjected. (3) 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or. (b4) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 4 of Article 12, 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. Similarly, 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. (5. ) 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. (6. ) The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, also apply ap- ply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions reduc- tions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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 enter- prise, be deductible under the same conditions as if they had been contracted to a resi- dent of the first-mentioned State. 5. 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 require- ment 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, therewith which is other otheer 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, also apply to persons who are not residents residdents 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 otheer 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. 3activies. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or of family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements distribursements 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. 54. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, . directly.or inderectly 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 ourdensome than the taxation and connected requirements to which other otheer similar enterprises of the first-mentioned State are or may by subjected. 5. Nothing contained in this Article shall be subjectedconstrued as preventing Belgium : a) from taxing the profits attributable to a permanent establishment in Belgium of company which is a resident of Indonesia at the rate of tax provided by the Belgian law; b) from imposing the movable property prepayment on dividends derived ffrom a holding which is effectively connected with a permanent establishment maintained in Belgium by a company which is a resident of Indonesia. 6. The provisions of In this Article shall apply to Article, the teerm “taxation” means taxes which are the subject of this Agreement.

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, 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, circumstances are or may 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 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on .on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that Stateresident. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 53. 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 Contracting 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. 4. 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, reliefs and reductions for tax purposes which are granted to individuals so residents. 5. Where a Contracting State grants tax incentives to its nationals designed to promote economic development in accordance with its national policy and criteria, it shall not be construed as discrimination under this Article. 6. The provisions of paragraph 2 and 3 of this Article shall not apply to the Vietnamese profit remittance tax and the Vietnamese taxation in respect of agriculture production activities. 7. Notwithstanding the provisions of this Article, for so long as Vietnam continues to grant to investors licenses under the Law on Foreign Investment in Vietnam, which specify the taxation to which the investor shall be subjected, the imposition of such taxation shall not be regarded as breaching the terms of paragraphs 2 and 3 of this Article. 8. The provision of this Article shall apply only to the taxes which are the subject subjected of this Agreement.

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 therewith that is other or more burdensome than the taxation and connected requirements to which nationals of that other Contracting 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, shall also apply to persons who are not residents of one or both of the Contracting States. However, for the purposes of United States taxation, United States nationals who are subject to tax on a worldwide basis are not in the same circumstances as nationals of who are not residents of the United States. 2. The taxation on a permanent establishment which that an enterprise of a Contracting State has in the other Contracting State shall not be less favourably favorably levied in that other Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activities. 3. Nothing in The provisions of paragraphs 1 and 2 of this Article shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs reliefs, and reductions for tax taxation purposes on account of civil status or family responsibilities which that it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 8 of Article 1111 (Interest), or paragraph 6 7 of Article 12, 12 (Royalties) apply, interest, royalties 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 Contracting State. Similarly, 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 the first-mentioned resident, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned Contracting State. 5. 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 Contracting State to any taxation or any requirement connected therewith which that is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned Contracting State are or may be subjected. 6. Nothing in this Article shall be construed as preventing either Contracting State from imposing a tax as described in paragraph 10 of Article 10 (Dividends) or paragraph 7 of Article 11 (Interest). 7. The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply to the taxes which are the subject of this Agreementevery kind and description.

NON-DISCRIMINATION. 1. Nationals The nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, therewith which is other or more burdensome burdensome, than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, circumstances and under the same conditions are or may 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 other State carrying on the same activitiesactivities in the same circumstances and under the same conditions. 3. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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 Contracting 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 that first-mentioned State are or may be subjectedsubjected in the same circumstances and under the same conditions. 64. The provisions Nothing contained in paragraphs 1, 2 and 3 of this Article shall apply be construed as - (a) obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions which it grants to its own residents; (b) affecting any provisions of the tax laws of the respective Contracting States regarding the imposition of tax on non-resident persons as such; (c) obliging a Contracting State to grant to nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which it grants to its own citizens who are not resident in that Contracting State or to such other persons as may be specified in the taxation laws of that Contracting State; and (d) affecting any provisions of the tax laws of the respective Contracting States regarding any tax concessions granted to persons fulfilling specified conditions. 5. In this Article the term "taxation" means taxes which are the subject of this Agreement.

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 Contracting State in the same circumstances, in particular with respect to residence, circumstance are or may be subjected. This provision shall, notwithstanding the provisions of Article 11 (Personal Scope), 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and or reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 8 7 of Article 1111 (Interest), or paragraph 6 of Article 1212 (Royalties), apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State 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. Similarly, 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. 54. 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. 65. The provisions of In this Article shall apply to Article, the term “taxation” means taxes which are the subject of this AgreementConvention.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. 5. 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 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 first·mentioned State are or may be subjected. 6. The provisions of this Article 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. 7. The provisions of this Article shall only apply to the taxes which are the subject of this AgreementConvention.

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, circumstances are or may be subjected. This provision shall, notwithstanding the provisions of Article 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 other State carrying on the same activities. This provision shall not be construed as preventing a Contracting State from charging the profits of a permanent establishment which a company of the other Contracting State has in the first-mentioned State at a rate of tax which is higher than that imposed on the profits of a similar company of the first-mentioned Contracting State, nor as being in conflict with the provisions of paragraph 3 of Article 7 of this Agreement. 3. Nothing in this Article article shall be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; ornationals. (b) nationals 4. Nothing in this article shall be construed as imposing a legal obligation on a Contracting State to extend to the residents of the other Contracting State those personal allowances, reliefs and reductions for tax purposes 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-first mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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 Stateparty. 5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, 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. 6. The Except where the provisions of article 9, paragraph 7 of article 11, or paragraph 6 of article 12 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. Similarly, 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 shall apply to article, the term “taxation” means taxes which are the subject of this Agreement.

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, 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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 53. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, 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. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, paragraph 6 of Article 12 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. 5. The provisions of paragraphs 2 and 3 of this Article shall not apply to the Vietnamese income remittance tax which, in any case shall not exceed ten per cent of the gross amount of the income remitted, and the Vietnamese taxation in respect of agricultural production activities. 6. Notwithstanding the provisions of this Article, for so long as either Contracting State continues to grant to investors licenses under the Law on Foreign Investment in that State, which specify the taxation to which the investor shall be subjected, the imposition of such taxation shall not be regarded as breaching the terms of paragraphs 2 and 3 of this Article. 7. The provisions of this Article shall apply only to the taxes which are the subject of this Agreement.

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, 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. 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State it grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. Provided that nothing in this paragraph shall be construed as preventing a Contracting State from imposing any obligation to withholding tax from such payments. 5. 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. 6. Where a Contracting State grants tax incentives to its nationals designed to promote economic or social development in accordance with its national policy and criteria, it shall not be construed as discrimination under this Article. 7. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, 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 provi- sions of Article article 1, also apply to persons who are not residents of one or both of the Contracting States. 2. Stateless persons who are residents of a Contracting State shall not be subjected in either Contracting State to any taxation or any re- quirement 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, in particular with re- spect to residence, are or may be subjected. 3. The taxation on a permanent establishment which an enterprise enter- prise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied lev- ied on enterprises of that other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowancesal- lowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that Stateresi- dents. 4. Except where the provisions of paragraph 1 of Article article 9, paragraph 8 para- graph 6 of Article article 11, or paragraph 6 of Article 12, article 12 apply, interest, royalties xxx- xxxxxx and other disbursements paid by an enterprise of a Contracting ARTICLES 24 AND 25 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. Similarly, any debts of an enterprise of a Con- tracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be de- ductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. 5. 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 con- nected therewith which is other or more burdensome than the taxation taxa- tion and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. 6. The provisions of this Article shall article shall, notwithstanding the provi- sions of article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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 property of such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. 54. Enterprises of a Contracting State, the capital property 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. 65. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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 11 of this Agreement, also apply to persons who are not residents of one or both of the Contracting States. 2. The taxation on a permanent establishment establishment, which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs relieves and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 5 of Article 11, or paragraph 6 of Article 1212 of this Agreement , 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. Similarly, 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 Contracting State. 4. Nothing in this Article shall be interpreted 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 third state or its residents by virtue of the formation of a customs union, economic union, a free trade area or any regional or sub- regional arrangement relating wholly or mainly to taxation or movement of capital to which such the first-mentioned Contracting State may be a party. 5. 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. 6. The provisions of this Article shall notwithstanding the provisions of Article 2 of this Agreement apply to the taxes which are the subject of this Agreementevery kind and description.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 4 of Article 12, 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. Similarly, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, 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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 6 of Article 11, 11 or paragraph 6 of Article 12, 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. 54. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, indirectly by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned Contracting 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-first- mentioned State are or may be subjected. 5. The provisions of paragraphs 2 and 4 of this Article shall not apply to the Vietnamese profit remittance tax, which in any case shall not exceed 10 per cent of the gross amount of profits remitted, and the Vietnamese taxation in respect of agricultural production activities, provided that the taxation of residents of Hungary so determined shall not be more burdensome than the taxation of residents of any third State. 6. 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, reliefs and reductions for tax purposes which are granted to individuals so resident. 7. The provisions of this Article shall apply only to the taxes which are the subject of this Agreement. 8. Notwithstanding the provisions of this Article, for so long as Vietnam continues to grant to investors licenses under the Law on Foreign Investment in Vietnam, which specify the taxation to which the investor shall be subjected, the imposition of such taxation shall not be regarded as breaching the terms of paragraphs 2 and 4 of this Article, provided that the taxation of residents of Hungary so determined shall not be more burdensome than the taxation of residents of any third State.

NON-DISCRIMINATION. 1. Nationals The 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. 2. 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 that other the State concerned in the same circumstances, in particular with respect to residence, circumstances are or may 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. 23. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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 that first-mentioned State are or may be subjected. 5. Except where the provisions of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12 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. Similarly, 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. 6. The provisions of In this Article shall apply Article, the term "taxation" means taxes to the taxes which are the subject of this AgreementAgreement applies.

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, 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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing , provided that this paragraph shall not prevent that other State from imposing on the profits attributable to a permanent establishment in this Article shall be construed as obliging that State of a Contracting State to grant to: (a) residents company which is a resident of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants further tax not exceeding 10 per cent on such profits as far as they are remitted from the permanent establishment to its own nationals who are the head office. Moreover, this paragraph shall not residents apply to the taxation of that State permanent establishments in Vietnam of enterprises in respect of oil exploration or to such other persons as may be specified production activities or in respect of activities which in the taxation laws case of that StateVietnamese enterprises are subject of activities which in the case of Vietnamese enterprises are subject to tax under the Law on Agriculture Land Using Tax. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 7 of Article 12, 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-first- mentioned State. 54. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, indirectly by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned Contracting 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. Contributions paid by, or on behalf of, an individual who is a resident of a Contracting State to a pension plan that is recognized for tax purposes in the other Contracting State will be treated in the same way for tax purposes in the first- mentioned State as a contribution paid to a pension plan that is recognized for tax purposes in that first-mentioned State, provided that: a. such individual was contributing to such pension plan before he become a resident of the first-mentioned State; and b. the competent authority of the first-mentioned State agrees that the pension plan corresponds to a pension plan recognized for tax purposes by that State. For the purpose of this paragraph, "pension plan" includes a pension plan created under a public social security system. 6. Nothing 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, reliefs or deductions for tax purposes on account of civil status or family responsibilities which are granted to individuals so resident. 7. The provisions of this Article shall apply only to the taxes which are the subject of this Agreement.

NON-DISCRIMINATION. 1. Nationals of a Contracting State Party shall not be subjected in the other Contracting State Party to any taxation or any requirement connected therewith, therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other State Party in the same circumstances, circumstances in particular with respect to residence, are or may 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 StatesParties. 2. Stateless persons who are residents of a Contracting Party shall not be subjected in either Contracting Party 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 Party concerned in the same circumstances, in particular with respect to residence, are or may be subjected. 3. The taxation on a permanent establishment which an enterprise of a Contracting State Party has in the other Contracting State Party shall not be less favourably levied in that other State Party than the taxation levied on enterprises of that other State Party carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State Party to grant to: (a) to residents of the other Contracting State Party any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 4 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State Party to a resident of the other Contracting State Party 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 StateParty. Similarly, any debts of an enterprise of a Contracting Party to a resident of the other Contracting Party 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 Party. 5. Enterprises of a Contracting StateParty, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting StateParty, shall not be subjected in the first-mentioned State Party 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 that first-mentioned State Party are or may be subjected. 6. The provisions of In this Article shall apply to the term "taxation" means taxes which are the subject of this Agreement.

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 11 (Personal Scope), also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 8 7 of Article 1111 (Interest), or paragraph 6 of Article 1212 (Royalties), 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. Similarly, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply to the taxes which are the subject of this Agreementevery kind and description.

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, circumstances are or may 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. 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. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 4 of Article 12, 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. Similarly, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, 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 Sate 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. 4. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) individual residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which it grants to its own nationals who are not resident in that Contracting Sate or to such other persons as may be specified in the taxation laws of that Contracting State. 5. Where a Contracting State grants tax incentives exclusively to its nationals designed to promote economic or social developments in accordance with its national policy and criteria, that limitation shall not be construed as discrimination under this Article. 6. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, 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, 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, 11 or paragraph 6 of Article 12, 12 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. Similarly, 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 (property) of such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. 54. Enterprises of a Contracting State, the capital (property) 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 prevent South Africa from imposing on the profits attributable to a permanent establishment in South Africa of a company, which is a resident of Belarus, a tax at a rate which does not exceed the rate of normal tax on companies by more than five percentage points. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. 5. 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-first- mentioned State are or may be subjected. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, 11 or paragraph 6 of Article 12, 12 of this Agreement apply, interest, royalties 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. 54. 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. The provisions of paragraphs 2 and 4 of this Article shall not apply to the Vietnamese profit remittance tax, which in any case shall not exceed 10 per cent of the gross amount of profits remitted, and the Vietnamese taxation in respect of oil exploration or production activities or in respect of agricultural production activities. 6. 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, reliefs and reductions for tax purposes which are granted to individuals so resident. 7. The provisions of this Article shall apply only to the taxes which are the subject of this Agreement. 8. Notwithstanding the provisions of this Article, for so long as Vietnam continues to grant to investors licenses under the Law on Foreign Investment in Vietnam, which specify the taxation to which the investor shall be subjected, the imposition of such taxation shall not be regarded as breaching the terms of paragraphs 2 and 4 of this

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 Contracting 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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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 Contracting State concerned in the same circumstances, in particular with respect to residence, are or may be subjected. 3. 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 Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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 Contracting State. 5. 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 Contracting 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 Contracting State are or may be subjected. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, therewith which is other otheer 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, also apply to persons who are not residents residdents 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 otheer 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. 3activies. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or of family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements distribursements 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. 54. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, . directly.or inderectly 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 ourdensome than the taxation and connected requirements to which other otheer similar enterprises of the first-mentioned State are or may by subjected. 5. Nothing contained in this Article shall be subjectedconstrued as preventing Belgium : a) from taxing the profits attributable to a permanent establishment in Belgium of company which is a resident of Indonesia at the rate of tax provided by the Belgian law; b) from imposing the movable property prepayment on dividends derived ffrom a holding which is effectively connected with a permanent establishment maintained in Belgium by a company which is a resident of Indonesia. 6. The provisions of In this Article shall apply to Article, the teerm "taxation" means taxes which are the subject of this Agreement.

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, also apply ap- ply to persons who are not residents of one or both of the Contracting States. 2. 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 subject- ed. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions reduc- tions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. 5. 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 require- ment 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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 11 (Personal scope), also apply to persons who are not residents of one or both of the Contracting States. 2. 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. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 99 (Associated enterprises), paragraph 8 7 of Article 1111 (Interest), or paragraph 6 of Article 1212 (Royalties), 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. Similarly, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes covered), apply to the taxes which are the subject of this Agreementevery kind and description.

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, 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, 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, 11 or paragraph 6 of Article 12, 12 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. 54. 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 that first-mentioned State are or may be subjected. 5. Nothing contained in this Article shall prevent South Africa from imposing on the profits attributable to a permanent establishment in South Africa of a company, which is a resident of Nigeria, a tax at a rate which does not exceed the rate of normal tax on companies by more than five percentage points. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 4 of Article 12, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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 11 of this Agreement, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 or paragraphs 4 of Article 11, 11 or paragraph 6 of Article 12, 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. 5. 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. 6. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, 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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. 54. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, indirectly by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned Contracting 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-first- mentioned State are or may be subjected. 5. The provisions of paragraphs 2 and 4 of this Article shall not apply to the Vietnamese profit remittance tax, which in any case shall not exceed 10 per cent of the gross amount of profits remitted, and the Vietnamese taxation in respect of agricultural production activities. 6. 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, reliefs and reductions for tax purposes which are granted to individuals so resident. 7. The provisions of this Article shall apply only to the taxes which are the subject of this Agreement. 8. Notwithstanding the provisions of this Article, for so long as Vietnam continues to grant to investors licenses under the Law on Foreign Investment in Vietnam, which specify the taxation to which the investor shall be subjected, the imposition of such taxation shall not be regarded as breaching the terms of paragraphs 2 and 4 of this Article.

NON-DISCRIMINATION. 1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement requirements connected therewith, 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, 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 of Article 12, 12 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-first- mentioned State. 54. 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 requirements 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. The non taxation of Qatari nationals under Qatari tax law shall not be regarded as a discrimination under the provision of this Article. 6. The provisions of In this Article shall apply to the term “taxation” means taxes which are the subject of this Agreement.

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 that the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 7 of Article 12, 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. Similarly, 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. 54. 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. 65. The Notwithstanding the preceding provisions of this Article shall apply Article, the Philippines may limit to its citizens the taxes which are enjoyment of tax incentives granted under: a) the subject Investment Incentives Act (Republic Act No. 6135), the Investment Incentives Program for the Tourism Industry (Presidential Decree No. 535) or the Agricultural Investment Incentives Act (Presidential Decree No. 1159) so far as it was in force on, and has not been modified since, the date of signature of this AgreementConvention, or has been modified only in minor respects so as not to affect its general character; or b) any enactment adopted by the Philippines in pursuance of its program of economic development which may be determined by mutual agreement between the Governments of the two Contracting States.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, or paragraph 6 of Article 13 apply, interest, royalties royalties, fees for technical services 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. 5. 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. 6. The provisions of this Article shall apply to the taxes which are the subject of covered under this Agreement.

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, especially with respect to residence, are or may be subjected. (2) 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 that other the State concerned in the same circumstances, in particular with respect to residence, circumstances are or may 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. (3) 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants only to its own residents; or. (b4) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 5 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. (5. ) 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. (6. ) The provisions of this Article shall apply to the taxes which are the subject of covered by this Agreement.

NON-DISCRIMINATION. 1. Nationals The nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, 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, circumstances are or may be subjected. This provision shall, notwithstanding Provided that nothing in this Article shall be interpreted as imposing a legal obligation on either Contracting State to extend to the provisions of Article 1, also apply to persons who are not residents of one the other, the benefit of any treatment, preference or both privilege which may be accorded to any other state or its residents by virtue of the Contracting Statesformation of a customs union, economic union, a free trade area or any regional or sub-regional arrangement relating wholly or mainly to taxation or movement of capital to which such State may be a party. 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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 that first-mentioned State are or may be subjected. 64. The provisions of Nothing in this Article shall apply be construed as obliging: (a) a Contracting State to grant to individuals who are residents of the taxes other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; (b) Malaysia to grant to nationals of Kuwait who are not residents in Malaysia those personal allowances, reliefs and reductions for tax purposes which are by law available on the subject date of signature of this AgreementAgreement only to nationals of Malaysia who are not residents in Malaysia. 5. Nothing in this Article shall be construed so as to prevent either Contracting State from limiting to its nationals the enjoyment of tax incentives designed to promote economic development in that State. 6. In this Article, the term "taxation" means taxes to which this Agreement applies.

NON-DISCRIMINATION. 1. Nationals of a Contracting State shall not be subjected in the other Contracting State 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, circumstances are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, 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 other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging preventing a Contracting State to grant to: (a) residents from charging the profits of a permanent establishment which a company of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which has in the first-mentioned State at a rate of tax which is higher than that imposed on the profits of a similar company of the first mentioned Contracting State grants to its own nationals who are not residents State, nor as being in conflict with the provisions of that State or to such other persons as may be specified in the taxation laws paragraph 3 of that StateArticle 7 of this Convention. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, paragraph 6 of Article 12, or paragraph 6 of Article 12, 14 apply, interest, royalties royalties, fees for technical services and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, 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. 54. Enterprises of a Contracting State, 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. 65. The provisions of Nothing in this Article shall apply be construed as obliging a Contracting State to grant to residents of the taxes other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which are the subject of this Agreementit grants to its own residents.

NON-DISCRIMINATION. 1. Nationals of a Contracting State territory shall not be subjected in the other Contracting State territory 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 territory in the same circumstances, in particular with respect to residence, are or may 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 Statesterritories. 2. The taxation on a permanent establishment which an enterprise of a Contracting State territory has in the other Contracting State territory shall not be less favourably levied in that other State territory than the taxation levied on enterprises of that other State territory carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State territory to grant to: (a) to residents of the other Contracting State territory any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to residents in its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that Stateterritory. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State territory to a resident of the other Contracting State territory 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 Stateterritory. 54. Enterprises of a Contracting Stateterritory, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting Stateterritory, shall not be subjected in the first-mentioned State territory 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 territory are or may be subjected. 65. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs relief and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, 11 or paragraph 6 of Article 12, 12 of this Agreement 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 duductible under the same conditions as if they had been paid to a resident of the first-mentioned State. 54. 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 thererwith 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. The provisions of paragraphs 2 and 4 of this Article shall not apply to the Vietnamese profif remittance tax, which in any case shall not exceed 10 per cent of the gross amount of profits remitted, and the Vietnamese taxation in respect of oil exploration or production activities or in respect of agricultural production activities. 6. 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, relieves and reductions for tax purposes which are granted to individuals so resident. 7. The provisions of this Article shall apply only to the taxes which are the subject of this Agreement.

NON-DISCRIMINATION. 1. Nationals of a Contracting State Party shall not be subjected in the other Contracting State Party 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 Party in the same circumstances, in particular with respect to residence, are or may 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 StatesParties. 2. The taxation on a permanent establishment which an enterprise of a Contracting State Party has in the other Contracting State Party shall not be less favourably levied in that other State Party than the taxation levied on enterprises of that other State Party carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State Party to grant to: (a) to residents of the other Contracting State Party any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State Party to a resident of the other Contracting State Party 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 StateParty. 54. Enterprises of a Contracting StateParty, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting StateParty, shall not be subjected in the first-mentioned State Party 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 Party are or may be subjected. 65. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, residence are or may be subjected. This provision shall, 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 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals . This provision shall not be construed as preventing a Contracting State from charging the profits of a permanent establishment which a company of the other Contracting State those personal allowances, reliefs and reductions for has in the first mentioned State at a rate of tax purposes which is higher than that imposed on the first-profits of a similar company of the first mentioned Contracting State grants to its own nationals who are not residents State, nor as being in conflict with the provisions of that State or to such other persons as may be specified in the taxation laws paragraph 3 of that StateArticle 7. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 12 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. 54. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, 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 requirements 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. 65. The provisions of this Article shall apply to the taxes which are the subject of covered by this Agreement.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. 5. 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. 6. The provisions of In this Article shall apply to Article, the term “taxation” means taxes which are the subject of this AgreementConvention.

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, 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 6 of Article 10, paragraph 7 or 8 of Article 11, or paragraph 6 or 7 of Article 12, or paragraph 3 or 4 of Article 20 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. Similarly, 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. 54. 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 either Contracting State to grant to individuals not resident in that State any of the personal allowances, reliefs and reductions for tax purposes which are granted to individuals so resident or to its nationals. 6. The provisions of this Article shall apply to the taxes which are the subject of this AgreementConvention.

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, 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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 5 of Article 12, 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. Similarly, 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. 5. 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. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

NON-DISCRIMINATION. 1. Nationals of a Contracting State Party shall not be subjected in the other Contracting State Party to any taxation or any requirement requirements connected therewith, therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other State Party in the same circumstances, in particular with respect to residence, are or may 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 StatesParties. 2. Stateless persons who are residents of a Contracting Party shall not be subjected in either Party 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 Party concerned in the same circumstances, in particular with respect to residence, are or may be subjected. 3. The taxation on a permanent establishment which an enterprise of a Contracting State Party has in the other Contracting State Party shall not be less favourably levied in that other State Party than the taxation levied on enterprises of that other State Party carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State Party to grant to: (a) to residents of the other Contracting State Party any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 of Article 12, 12 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State Party to a resident of the other Contracting State Party 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 StateParty. 5. Enterprises of a Contracting StateParty, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting StateParty, shall not be subjected in the first-mentioned State Party to any taxation or any requirement requirements connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State Party are or may be subjected. 6. The non-taxation of Qatari nationals under Qatari tax law shall not be regarded as discrimination under the provisions of this Article. 7. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

NON-DISCRIMINATION. 1. Nationals National s of a Contracting State shall not be subjected in the other Contracting 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, circumstances are or may 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 the taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 12 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting 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. Similarly, 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. 54. 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-first- mentioned State are or may be subjected. 65. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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 11 of this Agreement, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 5 of Article 11, or paragraph 6 5 of Article 12, 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. Similarly, 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. 5. 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. 6. The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, 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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 7 of Article 12, 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 profit of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. 54. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, 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-first- mentioned State are or may be subjected. 65. The provisions of paragraphs 2 and 4 shall not be construed as preventing a Contracting State from charging the profits of a permanent establishment which an enterprise of the other Contracting State has in the first-mentioned State at a rate of tax which is higher than that imposed on the profits of a similar enterprise of the first- mentioned Contracting State. However, the first-mentioned State may not exercise in respect of a resident of the other Contracting State a higher or more burdensome taxation than the taxation which that State would exercise in respect of a resident of a third State. 6. Nothing contained in this Article shall apply be construed as obliging either Contracting State to grant to individuals not resident in that State any of the taxes personal allowances, relieves and reductions for tax purposes which are granted to individuals so resident. 7. Notwithstanding the subject provisions of this AgreementArticle, for so long as a Contracting State continues to grant to foreign investors licenses under a Law on Foreign Investment in that State, which specify the taxation to which the investor shall be subjected, the imposition of such taxation shall not be regarded as breaching the terms of paragraphs 2 and 4 of this Article.

NON-DISCRIMINATION. 1. Nationals The nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, 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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 6 of Article 11, or paragraph 6 of Article 12, 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. Similarly, 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. 54. 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 Contracting 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 that first-mentioned State are or may be subjected. 65. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

NON-DISCRIMINATION. 1. Nationals The 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, 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 9 of Article 11, paragraph 6 of Article 12 or paragraph 6 of Article 1213, apply, interest, royalties royalties, fees for technical services 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, provided that the provisions of domestic law of that Contracting State have been complied with in respect of withholding tax. Similarly, 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. 54. 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 that first-mentioned State are or may be subjected. 65. The provisions of In this Article shall apply Article, the term "taxation" means taxes to the taxes which are the subject of this AgreementAgreement applies.

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, also apply to persons who are not residents of one or both of the Contracting States. 2. 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, in particular with respect to residence, are or may be subjected. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, or paragraph 6 4 of Article 12, 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. 5. 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. 6. Contributions paid by, or on behalf of, an individual who exercises employment or self-employment in a Contracting State to a pension fund that is recognised for tax purposes in the other Contracting State shall be treated in the same way for tax purposes in the first-mentioned State as a contribution paid to a pension fund that is recognised for tax purposes in that first-mentioned State, provided that: a) such individual was contributing to such pension fund before he became a resident of the first- mentioned State; and b) the competent authority of the first-mentioned State agrees that the pension fund generally corresponds to a pension fund recognised for tax purposes by that State. 7. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

NON-DISCRIMINATION. 1. (a) 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, also apply to persons who are not residents of one or both of the Contracting States. (b) For the purposes of sub-paragraph (a), it is understood that an individual, legal person, partnership or association who or which is a resident of a Contracting State is not placed in the same circumstances as an individual, legal person, partnership or association who or which is not a resident of that State ; this shall apply whatever the definition of nationality, even if legal persons, partnerships or associations are deemed to be nationals of the Contracting State of which they are residents. 2. The taxation on of a permanent establishment which that an enterprise of a Contracting State has in the other Contracting State, or of a fixed base that a resident of one Contracting State has available in the other Contracting State for the purpose of performing independent personal services, shall not be less favourably favorably levied in that other State than the taxation levied on enterprises or residents of that other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 5 of Article 11, or paragraph 6 5 of Article 12, 12 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shallshall be deductible, for the purpose of determining the taxable profits of such that enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly, 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 that enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. 54. 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-first- mentioned State are or may be subjected. 5. The exemptions and other advantages provided by the tax laws of a Contracting State for the benefit of that State or local authorities or of their statutory bodies of either which carry on a non-business activity shall apply under the same conditions respectively to the other Contracting State or local authorities or to their statutory bodies which carry on the same or similar activity. Notwithstanding the provisions of paragraph 7, the provisions of this paragraph shall not apply to taxes or duties payable in consideration for services rendered. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to taxes of every kind and description. 7. If any bilateral treaty or agreement between the taxes which are the subject of Contracting States, other than this AgreementConvention, includes a non-discrimination clause or a most-favoured nation clause, it is understood that such clauses shall not apply in tax matters.

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, therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other Contracting State in the same circumstances, in particular with respect to residence, circumstances are or may be subjected. This provision The provisions of this paragraph 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 Contraciing State has in the other Contracting State shall not be less favourably levied in that other Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activities. 3. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 12, 12 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 Contracting State. 54. 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 Contracting 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 Contracting State are or may be subjected. 65. The provisions of Nothing contained in this Article shall apply be construed as obliging a Contracting State to grant to residents of the taxes other Contracting State any personal allowances, reliefs and reductions for tax purposes which are by law available only to residents of the subject of this Agreementfirst-mentioned Contracting State.

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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in The provisions of this Article shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or. (b) 4. Moreover nothing in this Article shall be construed as obliging a Contracting State to grant to nationals of the other Contracting State not resident in the first-mentioned State those personal allowancesallowance, reliefs and reductions for tax purposes which are by law available on the first-date of signature of this Agreement only to nationals of the first mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified therein who are not resident in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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-first mentioned State are or may be subjected. 6. The provisions of In this Article shall apply to the term "taxation" means taxes which are the subject of this Agreement.

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, 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 5 of Article 11, or paragraph 6 4 of Article 12, 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. Similarly, 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. 54. 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. 65. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply to the taxes which are the subject of this Agreementevery kind and description.

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, 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. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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. (4) Nothing in this Article shall be construed as obliging a contracting State to grant to: (a) individual residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which it grants to its own nationals who are not resident in that Contracting State or to such other persons as may be specified in the taxation laws of that Contracting State. (5) Where a Contracting State grants tax incentives exclusively to its nationals designed to promote economic or social development in accordance with its national policy and criteria, that limitation shall not be construed as discrimination under this Article. (6. ) The provisions of this Article shall apply to the taxes which are the subject of this Agreement.

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, 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, circumstances are or may 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 other State carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 53. 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. 64. The Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12 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. 5. Nothing contained in this Article shall apply be construed as obliging either Contracting State to grant to individuals not resident in that State any of the personal allowances, reliefs and reductions for tax purposes which are granted to individuals so resident 6. In this Article the term "taxation" means taxes which are the subject of this Agreement.

NON-DISCRIMINATION. 1. Nationals or citizens of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, therewith which is other or more burdensome than the taxation and connected requirements to which nationals or citizens of that other Contracting State in the same circumstances, in particular with respect to residence, circumstances and under the same conditions are or may be subjected. This provision shallshall not be construed as obliging a Contracting State to grant to nationals of the other Contracting State not resident in the first- mentioned Contracting State those personal allowances, notwithstanding reliefs and reductions for tax purposes which are by law available only to citizens of the provisions of Article 1, also apply first-mentioned Contracting State or to such other persons as may be specified therein who are not residents of one or both of the resident in that Contracting StatesState. 2. The term "nationals or citizens" means: (a) all individuals possessing the nationality or citizenship of a Contracting State; and (b) all legal persons, partnerships and associations deriving their status as such from the law in force in a Contracting State. 3. 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 Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activitiesactivities in the same circumstances or under the same conditions. 34. Nothing in The provisions of this Article shall not be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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 Contracting 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 that first-mentioned Contracting State are or may be subjectedsubjected in the same circumstances and under the same conditions. 6. The provisions of In this Article shall apply to Article, the term "taxation" means taxes which are the subject of this Agreement.

NON-DISCRIMINATION. 1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement requirements connected therewith, 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, 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs relief and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 5 of Article 11, or paragraph 6 of Article 12, 12 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 firstmentioned State. 54. 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 requirements connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned firstmentioned State are or may be subjected. 65. The provisions of In this Article shall apply to the term “taxation” means taxes which are the subject of this Agreement.

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 third States, except nationals of Gulf Cooperation Council (GCC) member states in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons nationals 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 third States, except Gulf Cooperation Council (GCC) member states carrying on the same activities. 3. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 9, paragraph 8 4 of Article 11, 11 or paragraph 6 of Article 12, 12 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. 54. 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 the capital of which is wholly or partly owned or controlled, directly or indirectly, by residents of third states, except nationals of Gulf Cooperation Council (GCC) member states, This provision shall not be construed as restricting the right of the first-mentioned State of Qatar to grant tax exemptions under Chapter 6 of the Income Tax Decree Law No.11. of 1993 or any identical or substantially similar provisions which are enacted after the date of signature of the Agreement in addition to, or may be subjectedin place of, the aforementioned provisions. 65. The provisions of In this Article shall apply to the term “taxation” means taxes which are the subject of this Agreement.

NON-DISCRIMINATION. 1. Nationals The nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, 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, circumstances and under the same conditions are or may 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 the other State than the taxation levied on enterprises of that other State carrying on the same activitiesactivities in the same circumstances and under the same conditions. 3. Nothing in this Article shall be construed as obliging a Contracting State to grant to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 6 of Article 12, 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. 5. 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 Contracting 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 that first-mentioned State are or may be subjectedsubjected in the same circumstances and under the same conditions. 64. The provisions Nothing contained in paragraphs 1, 2 and 3 of this Article shall apply be construed as: (a) obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions which it grants to its own residents; (b) affecting any provisions of the tax laws of the respective Contracting States regarding the imposition of tax on non-resident persons as such; (c) obliging a Contracting State to grant to nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which it grants to its own citizens who are not resident in that Contracting State or to such other persons as may be specified in the taxation laws of that Contracting State; and (d) affecting any provisions of the tax laws of the respective Contracting States regarding any tax concessions granted to persons fulfilling specified conditions. 5. In this Article the term "taxation" means taxes which are the subject of this Agreement.

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 11 of this Agreement, also apply to persons who are not residents of one or both of the Contracting States. 2. 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. 3. 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. Nothing in this Article This provision shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs and reductions for tax taxation purposes on account of civil status or family responsibilities which it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 4. Except where the provisions of paragraph 1 of Article 9, paragraph 8 7 of Article 11, or paragraph 6 of Article 1212 of this Agreement, 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. Similarly, 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. 5. 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-first- mentioned State are or may be subjected. 6. The provisions of this Article shall apply to shall, notwithstanding the taxes which are the subject provisions of Article 2 of this Agreement, apply to taxes of every kind and description.

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 therewith that is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular particularly with respect to residencetaxation on worldwide income, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, shall 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 or fixed base that a resident or enterprise of a Contracting State has in the other Contracting State shall not be less favourably favorably levied in that other State than the taxation levied on enterprises or residents of that other State carrying on the same activities. 3. Nothing in The provisions of this Article paragraph shall not be construed as obliging a Contracting State to grant to: (a) to residents of the other Contracting State any personal allowances, reliefs reliefs, and reductions reduc- tions for tax taxation purposes on account of civil status or family responsibilities which that it grants to its own residents; or (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which the first-mentioned Contracting State grants to its own nationals who are not residents of that State or to such other persons as may be specified in the taxation laws of that State. 43. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 8 4 of Article 1111 (Interest), or paragraph 6 4 of Article 12, 12 (Royalties) apply, interest, royalties royal- ties, and other disbursements paid by an enterprise a resident of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprisethe first-mentioned resident, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly, any debts of a resident of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of the first-mentioned resident, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. 54. 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 that 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 a tax as described in paragraph 8 of Article 10 (Dividends). 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply to the taxes which are the subject of this Agreementevery kind and description imposed by a Contracting State or a political subdivision or local authority thereof.