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. (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) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, 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. 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. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) The provisions of this Article shall apply only to the taxes which are the subject of this Agreement.

NON-DISCRIMINATION. (1) Nationals . The nationals of a Contracting State shall not be subjected subject 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. (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 out the same activities, provided that this paragraph shall not: (a) prevent Vietnam from imposing on the profits attributable to a permanent establishment in Vietnam of a company which is a resident of Singapore further tax not exceeding 10% on such profits as far as they are remitted from the permanent establishment to the head office; (b) apply to the taxation of permanent establishments in Vietnam of Singaporean enterprises in respect of oil exploration or production activities which in the case of Vietnamese enterprises are subject to tax under the Law on Agriculture Land-Use Tax. 3. This provision Nothing in this Article shall not be construed as obliging a Contracting State state to grant to to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for taxation tax purposes on account of civil status or family responsibilities which it grants to its own residents.; or (3b) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services and other disbursements paid by an enterprise of a Contracting State to a resident nationals of the other Contracting State shallthose personal allowances, reliefs and reductions for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid tax purposes which it grants to a its own nationals who are not resident of the first-mentioned State. Similarly, any debts of an enterprise of a in that Contracting State or to a resident such other persons as may be specified in the taxation laws of the other that 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . 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 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. 3. This provision Nothing in this Article shall not be construed as obliging a Contracting State to grant to to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for taxation 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 residents of that State or to such other persons as may be specified in the taxation laws of that State. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) 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. (5) 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 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. 3. This provision Nothing in this Article shall not be construed as obliging a Contracting State to grant to to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for taxation 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. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 5 of Article 12 12, apply, interest, royalties, fees for technical services 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 Provided that nothing in this paragraph shall be construed as preventing a Contracting State from imposing any obligation to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of withholding tax from such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned Statepayments. (4) 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. (5) 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 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. (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. This provision Nothing in this Article shall not be construed as obliging a Contracting State to grant to to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for taxation 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 residents of that State or to such other persons as may be specified in the taxation laws of that State. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) 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. (5) 6. 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 Contracting State in the same circumstances, in particular with respect to residence, circumstances are or may be subjected. (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. This provision The provisions of this paragraph shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned 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) . Notwithstanding the provisions from paragraphs 1 to 4 of this Article, where a Contracting State imposes any taxation on its nationals which is other than the taxation it imposes on nationals of the other Contracting State for the purposes to promote economic development in accordance with its taxation laws, the imposition as such shall not be construed as discrimination under the meaning of this Article. 6. 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, circumstances are or may be subjected. (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 State, carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, 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. 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. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (4. Notwithstanding the provisions of paragraphs 1, 2 and 3, nothing in this Article shall affect the right of either Contracting State to grant an exemption or reduction of taxation in accordance with its domestic laws, regulations or administrative practices to its own nationals who are residents of that Contracting State. Such exemption or reduction, however, shall not apply in respect of such proportion of the capital of companies owned by persons who are nationals of the other Contracting State. 5) . 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, the benefit of any treatment, preference or privilege which may be accorded to any other Contracting State or its residents by virtue of the formation of a customs union, economic union, special agreements, a free trade area or by virtue of any regional or sub-regional arrangement relating wholly or mainly to movement of capital and/or taxation to which the first-mentioned Contracting State may be a party. 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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. (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) . 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. 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. 5. The provisions of this Article shall apply to the taxes which are the subject of this Agreement. 6. Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, paragraph 6 of Article 12 or paragraph 6 of Article 12 13 apply, interest, royalties, services 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. 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. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) 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. 3. This provision Nothing in this Article shall not be construed as obliging a Contracting State to grant to to: (a) residents of the other Contracting State any personal allowances, reliefs and reductions for taxation 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 residents in that Contracting State or to such other persons as may be specified in the taxation laws of that Contracting State. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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. (4) 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. (5) The provisions of 6. Where a Contracting State grants tax incentives to its nationals designed to promote economic development in accordance with its nationals policy and criteria, it shall not be construed as discrimination under this Article shall apply only to the taxes which are the subject of this AgreementArticle.

NON-DISCRIMINATION. (1) Nationals . A citizen 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 a citizen of that other State or of a third State, who is in the same circumstances, in particular with respect to residence, are is or may be subjected. This provision shall apply to persons who are not residents of one or both of the Contracting States. This provision shall not be construed as obliging a Contracting State to grant to citizens of the other Contracting State tax benefits granted by special agreements to citizens of a third State. (2) The taxation on a permanent establishment which an enterprise . A resident of a Contracting State which has a permanent establishment in the other Contracting State shall not be less favourably levied not, in that other State and with respect to income attributable to that permanent establishment, be subjected to more burdensome taxes than the taxation levied are generally imposed on enterprises residents of that other State or of a third State which are carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to permanent establishments of the residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account tax benefits granted by special agreements to permanent establishments of civil status or family responsibilities which it grants to its own residentsthe residents of a third State. (3) . Except where the provisions of paragraph 1 of Article 97 (Associated Enterprises), paragraph 7 4 of Article 11 (Interest), or paragraph 6 of Article 12 (Royalties) apply, interest, royalties, fees for technical services 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 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 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 capital Capital of such enterprisethe first-mentioned resident, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. (4) Enterprises . A company which is a resident 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 companies which are residents of the first-mentioned State (whether owned by residents of that State or of a third State) are or may be subjected. 5. Nothing in this Article shall prevent a Contracting State from imposing the tax described in paragraph 5 of Article 10 (5Dividends) or paragraph 7 of Article 11 (Interest). 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply only 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 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. (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 levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of the second sentence of paragraph 5 of Article 7 (Business Profits), paragraph 1 of Article 99 (Associated Enterprises), paragraph 9 of Article 10 (Dividends), paragraphs 4 and 7 of Article 11 or paragraph 6 (Interest), paragraphs 4 and 5 of Article 12 (Royalties), or paragraphs 3 and 4 of Article 22 (Other Income) of this Convention apply, interest, royalties, fees for technical services 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 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which 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) The provisions of . Nothing in this Article shall apply only be construed as obliging either Contracting State to grant to individuals not resident in that State any of the taxes personal allowances, reliefs and reductions for tax purposes which are the subject granted to individuals so resident or to its nationals. 6. Nothing in this Article shall be construed as preventing either Contracting State from imposing a tax as described in paragraph 7 of this Agreement.Article 10 (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. (2) . The taxation on of 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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-first- mentioned State are or may be subjected. (5) . The provisions of this Article shall apply only not 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 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. 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. 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. (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 favorably levied in that other Contracting 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) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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 State. (4) 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. (5) 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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 Contracting State in the same circumstances, in particular with respect to residence, circumstances are or may be subjected. (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 activitiesactivities in the same circumstances or under the same conditions. 3. This provision Where a Contracting State charges the profits of a permanent establishment which an enterprise of the other Contracting State has in the first-mentioned Contracting State at a rate of tax which is different from that imposed on the profits of a similar enterprise of the first-mentioned Contracting State, it shall not be construed as discrimination under this Article. 4. Nothing contained in this Article shall be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions deductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) 5. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 7 of Article 12 12, apply, interest, royalties, fees for technical services 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 State subject to the provisions of an enterprise domestic laws of a that 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. (4) 6. 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 subjectedsubjected in the same circumstances and under the same conditions. (5) The provisions of 7. In this Article shall apply only 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) 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. 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. (34) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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. (45) 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. (56) The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 9 of Article 11 or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) The provisions of . Nothing in this Article shall apply only be construed as obliging a Contracting State to grant to: (a) residents of the taxes other Contracting State any personal allowances, reliefs and reductions for tax purposes 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 residents of that Contracting State or to such other persons as may be specified in the subject taxation laws of that Contracting State. 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 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. (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. This provision Nothing in this Article shall not be construed as obliging a Contracting State to grant to to: (a) 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; 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 residents of that State or to such other individuals as may be specified in the taxation laws of that State. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) 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. (5) 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 only to the taxes which are the subject of this Agreement.

NON-DISCRIMINATION. (1) Nationals . The nationals of a Contracting State State, whether or not they are residents of one of the Contracting States, 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. (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 an enterprise of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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 condition 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements requirement to which other similar enterprises of the that first-mentioned State are or may be subjected. (5) The provisions of . Nothing in this Article shall apply only be construed so as to prevent the Philippines from limiting to its nationals the enjoyment of tax incentives granted under its laws. 6. Nothing in this Convention shall be construed as preventing the Philippines from taxing its citizens in accordance with its domestic legislation. 7. In this Article, the term "taxation" means the taxes to which are the subject of this AgreementConvention 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, 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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 4 of Article 11 11, or paragraph 6 4 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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 that which the taxation and connected requirements to which nationals of that the other State in the same circumstances, in particular with respect to residence, circumstances are or may be subjected. (2) . The taxation or relief of 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 Contracting State than the taxation levied on enterprises of that other State carrying on the same activities. activities in the same circumstances and under the same methods. (a) This provision 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 an account of civil status or family responsibilities responsibility which it grants to its own residents. (3b) Except where the provisions of paragraph 1 of Nothing in this Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services and other disbursements paid by an enterprise of shall be construed as imposing a legal obligation on a Contracting State to a resident extend to the residents of the other Contracting State shallState, for the purpose benefit of determining any treatment, preference or privilege which may be accorded to any other third country or its residents by virtue of the taxable profits formation of such enterprisea customs union, be deductible under the same conditions as if they had been paid a free trade area or by virtue of any regional or sub-regional arrangement relating wholly or mainly to a resident of taxation, to which the first-mentioned State. Similarly, any debts State may be a party pursuant to the practice of an enterprise of a either 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, 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 requirement to which other the similar enterprises of the first-mentioned that first -mentioned State are or may be subjected. (5) The provisions of . In this Article shall apply only to the term “taxation” means taxes of every kind and description which are the subject of this Agreement.

NON-DISCRIMINATION. (1) Nationals . A citizen of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewithconnected, therewith which is other or more burdensome than the taxation and connected requirements to which nationals a citizen of that other State or of a third State, who is in the same circumstances, in particular with respect to residence, are is or may be subjected. This provision 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 . A resident of a Contracting State that has a permanent establishment in the other Contracting State shall not be less favourably levied not, in that other State and with respect to income attributable to that permanent establishment, be subjected to more burdensome taxes than the taxation levied are generally imposed on enterprises residents of that other State or of a third State that are carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 7 4 of Article 11 (Interest), or paragraph 6 of Article 12 (Royalties) apply, interest, royalties, fees for technical services 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. Similarly, any debts of 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 capital of such enterprisethe first-mentioned resident, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. (4) Enterprises . A company that is a resident 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 that are residents of the first-mentioned State (whether owned by residents of that State or of a third State) are or may be subjected. 5. Nothing in this Article shall prevent a Contracting State from imposing the tax described in paragraph 5 of Article 10 (5) Dividends). 6. This provision shall not be construed as obliging a Contracting State to grant to citizens or residents of the other Contracting State tax benefits granted by special agreements to citizens or residents of 'a third State. 7. The provisions of this Article, notwithstanding the provisions of Article 2 (Taxes Covered), shall apply only 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 Contracting State in the same circumstances, in particular with respect to residenceresi- dence, are or may be subjected. 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 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. This provision The provisions of this paragraph shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 or 11, paragraph 6 of Article 12 or paragraph 3 of Article 20 apply, interest, royalties, fees for technical services royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other oth- er 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation taxa- tion and connected requirements to which other similar enterprises of the first-first- mentioned Contracting State are or may be subjected. (5) . The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only to the taxes which are the subject of this Agreementevery kind and description imposed on behalf of a Contracting State or of its political or administrative 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, 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. (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. This provision Stateless persons who are residents of a Contracting State shall not be construed as obliging a subjected in either Contracting State to grant any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to residents which nationals of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status concerned in the same circumstances are or family responsibilities which it grants to its own residentsmay be subjected. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) 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. (5) 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 only 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, are or may be subjected. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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-first- mentioned State. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) 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 only 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, 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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 or 11, paragraph 6 of Article 12 and paragraph 6 of Article 13 apply, interest, 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. SimilarlyWhen, any debts of an enterprise however, the domestic laws of a Contracting State to provide that a resident of tax shall be withheld at source and this obligation has not been fulfilled the other Contracting State shall, for the purpose of determining the taxable capital of such enterprise, aforesaid requirements may be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned Stateset aside. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the that first-mentioned State are or may be subjected. (5) 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 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 Sweden not resident in Malaysia those personal allowances, reliefs and reductions for tax purposes which are by law available on the date of signature of this Agreement only to nationals of Malaysia who are not resident in Malaysia. 6. In this Article, the term "taxation" means taxes to which are the subject of this AgreementAgreement applies.

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, circumstances in particular with respect to residence, are or may be subjected. (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 tax purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 8 of Article 12 12, apply, interest, royalties, royalties and 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. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the that first-mentioned State are or may be subjected. (5) The provisions of . In this Article shall apply only 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. (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. This provision 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. 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 reliefs, and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) 5. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) 6. The provisions of this Article shall only apply only 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 Contracting State in the same circumstances, in particular with respect to residence, circumstances are or may be subjected. (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. This provision The provisions of this paragraph shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 6 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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. (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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, paragraph 6 of Article 12, or paragraph 6 of Article 12 13 apply, interest, royalties, technical 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-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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-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 this Article shall shall, notwithstanding the provisions of Article 2, apply only to taxes of every kind and description. 6. The provisions in the taxes which are the subject previous paragraphs of this Agreementarticle will not limit, however, the application of the domestic provisions in order to prevent fiscal evasion.

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) . 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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. SimilarlyFor the purposes of this paragraph, any debts it is understood that, for the purposes of allowing deduction of an enterprise of interest payment to a non-resident, nothing in this paragraph shall prevent a Contracting State to from disallowing a resident of the other Contracting State shall, for the purpose of determining the taxable capital deduction of such enterprise, be deductible under interest payment if tax is not withheld on the same conditions as if they had been contracted to a resident of the first-mentioned Statepayment. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . 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, 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. (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) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, 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. 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. (4) 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 firstmentioned State are or may be subjected. (4. The provisions of paragraphs 2 and 3 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. 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. 6. 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. 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, 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) . 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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 or 8 of Article 11 11, or paragraph 6 4 or 5 of Article 12 12, or paragraph 3 or 4 of Article 20 apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-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 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . 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. 6. The provisions of this Article shall apply only to the taxes which are the subject of this Agreement.

NON-DISCRIMINATION. (1) Nationals . The nationals of a Contracting State one of the States 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. (2) . The taxation on a permanent establishment which an enterprise of a Contracting State one of the States 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 one of the States to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 7 of Article 12 apply, interest, royalties, fees for technical services royalties and other disbursements paid by an enterprise of a Contracting State one of the States 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. (4) . Enterprises of a Contracting Stateone of the States, 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 . In this Article the term ‘taxation’ means taxes of every kind and description. 6. With respect to the taxes referred to in Article 2, nothing in this Article shall apply only prevent the Philippines from limiting to its citizens or corporations the taxes which are enjoyment of tax incentives granted under Article 44 of Presidential Decree No. 1789, as amended by P.B. No. 391, otherwise known as the subject of this AgreementInvestment Policy Act.

NON-DISCRIMINATION. (1) Nationals . Individuals who are nationals of a Contracting State and residents of the other Contracting State shall not be subjected in the that 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 individuals who are nationals and residents of that other State in the same circumstances, in particular with respect to residence, circumstances are or may be subjected. (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 reliefs, and reductions for taxation purposes on account of civil status or family responsibilities which that it grants to its own residents. The provisions of this paragraph shall not prevent the application by either Contracting State of the taxes described in paragraph 7 of Article 10 (Dividends). (3a) Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 6 of Article 11 (Interest), or paragraph 7 of Article 11 or paragraph 6 of Article 12 (Royalties) apply, interest, 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 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. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose purposes 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. (b) Nothing in this Convention shall prevent the application of Article 212 of the French tax code (code général des impôts) as it may be amended from time to time without changing the general principle thereof or of any substantially similar provisions which may be enacted in addition to or in substitution for that provision (including provisions substantially similar to those applicable in the other Contracting State), to the extent that such application is consistent with the principles of paragraph 1 of Article 9 (Associated Enterprises). 4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply only to taxes of every kind and description imposed by a Contracting State or a political subdivision (in the taxes which are case of the subject of this AgreementUnited States) or local authority thereof.

NON-DISCRIMINATION. (1) Nationals . The nationals of a Contracting State State, whether or not they are residents of one of the Contracting States, 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. (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 of family responsibilities responsibility which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, of paragraph 7 of Article 11 or of paragraph 6 5 of Article 12 apply, interest, royalties, fees for technical services 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. 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned 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. (5) The provisions of . Nothing in this Article shall apply only be construed as preventing Belgium: (a) from taxing the total amount of the profits attributable to a permanent establishment in Belgium of a company being a resident of Thailand or of an association having its place of effective management in Thailand at the rate of tax provided by the Belgian law, but this rate may not exceed the maximum rate applicable to the taxes profits of companies which are residents of Belgium; (b) from imposing the subject movable property prepayment on dividends derived from a holding which is effectively connected with a permanent establishment or a fixed base maintained in Belgium by a company which is a resident of Thailand or by an association which has its place of effective management in Thailand and is taxable as a body corporate in Belgium. 6. In this AgreementArticle the term “taxation” means 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 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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 98, paragraph 7 of Article 11 10 or paragraph 6 of Article 12 11, apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned 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. (5) . The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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, connnected 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. (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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, 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. 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. (4) 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. The provisions of paragraphs 2 and 3 of this Article shall not apply to the Vietnamese profit remittance tax, other than the tax referred to in paragraph 2 of Article 10, and the Vietnamese taxation in respect of agricultural production activities. 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. 6. 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, 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 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 24 (Relief from Double Taxation), a United States national who is not a resident of the United States and a Spanish national who is not a resident of the United States are not in the same circumstances. (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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs 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 preventing either Contracting State from imposing a tax as described in Article 14 (3) Branch Tax). 4. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 7 of Article 11 (Interest), or paragraph 6 of Article 12 (Royalties) apply, interest, 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 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. 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. (4) 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 similarly situated enterprises of the first-mentioned State are or may be subjected. (5) 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply only 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, 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. (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) . Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 7 of Article 11 or paragraph 6 of Article 11 (Interests), or paragraph 4 of Article 12 (Royalties) apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned 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. (5) The . Notwithstanding the preceding provisions of this Article shall apply only Article, either Contracting State may, in the promotion of necessary industry or business, limit to its nationals the enjoyment of tax incentives granted by it. However, if such tax incentives should be granted to the taxes which are nationals of any third state, the subject nationals of this Agreementthe other Contracting State will also enjoy these benefits.

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, circumstances are or may be subjected. (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) . Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 7 of Article 11 or paragraph 6 of Article 11 (Interest), or paragraph 4 of Article 12 (Royalties) apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) The provisions of . Nothing contained in this Article shall apply only be construed as to prevent either Contracting State from limiting to its nationals the taxes enjoyment of tax incentives and any tax of a preferential nature designed in pursuance of its programme of economic development. 6. In this Article, the term “taxation” means taxes, which are the subject of this Agreement. 7. The competent authorities of the Contracting States may consult with each other on the mode of application 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 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 (General Scope), 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 Iceland who are not residents of the United 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) . Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 7 4 of Article 11 (Interest), or paragraph 6 of Article 12 (Royalties), apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. 5. Nothing in this Article shall be construed as preventing either Contracting State from imposing a tax as described in paragraph 8 of Article 10 (5) Dividends). 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply only 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or 11, paragraph 6 of Article 12 or paragraph 7 of Article 13 apply, interest, 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. 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of a third State, are or may be subjected. (5) . 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. 6. The provisions of this Article shall apply only 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 4 of Article 11 11, paragraph 4 of Article 12, paragraph 4 of Article 20, or paragraph 6 2 of Article 12 23 apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . Nothing 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 only to the taxes which are the subject referred to in Article 2 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 4 or 5 of Article 11 11, paragraph 4 or paragraph 6 5 of Article 12 12, or paragraphs 4 or 5 of Article 20 apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) The provisions of . Nothing contained in this Article shall apply only be construed as obliging either Contracting State to grant to individuals not resident in that State any of the taxes personal allowances, reliefs and reductions for tax purposes which are the subject of this Agreementgranted to individuals so resident or to its nationals.

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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 or 8 of Article 11 or 11, paragraph 6 or 7 of Article 12 or paragraph 4 or 5 of Article 21 apply, interest, 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. 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . Nothing 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 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. (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 levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision . (3) Nothing in 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 that it grants to its own residentsresidents or to its nationals. (34) Except where the provisions of paragraph 1 (1) of Article 9, paragraph 7 (6) or (7) of Article 11 11, paragraph (6) or paragraph 6 (7) of Article 12 or paragraph (4) or (5) of Article 20 of this Convention apply, interest, royalties, fees for technical services 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. (45) Enterprises 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. (56) The provisions of this Article shall apply only 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, are or may be subjected. (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 levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. 3. This provision Nothing in 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 that it grants to its own residents. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 6 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) Enterprises 5. Companies which 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) The provisions of 6. In this Article shall apply only to Article, the term "taxation" means taxes which that 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 State, in the same circumstances, in particular with respect to residence, are or may be subjected. (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) Except where the provisions of paragraph 1 (1) of Article 9, paragraph 7 (6) or (7) of Article 11 11, or paragraph 6 (6) or (7) of Article 12 of this Agreement apply, interest, royalties, fees for technical services 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. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) Nothing 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 own nationals. (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 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. (2) The taxation on a permanent establishment which an enterprise . Stateless persons who are residents of a Contracting State has in the other either Contracting State shall not be less favourably levied subjected in that either Contracting State to any taxation or any requirement connected therewith, which is other State or more burdensome than the taxation levied on enterprises and connected requirements to which nationals of that other the State carrying on concerned in the same activitiescircumstances, in particular with respect to residence, are or may be subjected. 3. This provision provisions of this Article shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal tax allowances, reliefs and reductions for taxation purposes on account which are granted by the first-mentioned State to the residents of civil status or family responsibilities which it grants to its own residentsthe third States by force of existing tax agreements. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 article 12, apply, interest, royalties, fees for technical services 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. (4) 5. 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 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 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, 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. The provisions of this paragraph shall not be construed as obliging a Contracting State to grant to citizens of the other Contracting State tax benefits granted by special agreements to nationals of a third state. 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 of 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. This provision Nothing contained in this Article shall not be construed interpreted as obliging a Contracting State to grant give to residents individuals not resident in that State the right to any of the other Contracting State any personal allowances, reliefs and reductions for taxation tax purposes on account which are granted to individuals who are residents of civil status or family responsibilities which it grants to its own residentsthat State. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) 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 State are or may be subjected. (5) 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . The provisions of this Article shall apply only to the taxes which are the subject of covered by 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 ContractingStates. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 9 of Article 11 or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) The provisions of . Nothing in this Article shall apply only be construed as obliging a Contracting State to grant to: (a) residents of the taxes other Contracting State any personal allowances, reliefs and reductions for tax purposes 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 residents of that Contracting State or to such other persons as may be specified in the subject taxation laws of that Contracting State. 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 AgreementArticle.

NON-DISCRIMINATION. (1) Nationals . The nationals of a Contracting State State, whether or not they are residents of one of the Contracting States, 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 6 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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 condition 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned 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. (5) The provisions of . In this Article shall apply only to the term "taxation" means those taxes which are the subject of covered by 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 Contracting State in the same circumstances, in particular with respect to residence, circumstances are or may be subjected. (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) . Except where the provisions of paragraph 1 of Article 98 (Associated Enterprises), paragraph 7 of Article 11 or paragraph 6 of Article 12 10 (Interests), or paragraph 4 of Article 11 (Royalties) apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned 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-that first- mentioned State are or may be subjected. (5) The . Notwithstanding the preceding provisions of this Article shall apply only Article, either Contracting State may, in the promotion of necessary industry or business, limit to its nationals the enjoyment of tax incentives granted by it. However, if such tax incentives should be granted to the taxes which are nationals of any third State, the subject nationals of this Agreementthe other Contracting State will also enjoy these benefits.

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. (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. This provision Nothing in 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. (3) 4. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 7 of Article 11 or (Interest), paragraph 6 of Article 12 (Royalties) or paragraph 3 of Article 21 (Other Income) apply, interest, royalties, fees for technical services 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. (4) 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. (5) 6. The provisions of this Article shall apply only to the taxes which are the subject referred to in Article 2 (Taxes Covered) of this AgreementConvention.

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 that which the taxation and connected requirements to which nationals of that the other State in the same circumstances, in particular with respect to residence, circumstances are or may be subjected. (2) . The taxation or relief of 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 enterprise of that other State carrying on the same activities. This provision activities in the same circumstances and under the same methods. (a) 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 responsibility or otherwise which it grants to its own residents. (3b) Except where the provisions of paragraph 1 of nothing in this Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services and other disbursements paid by an enterprise of shall be construed as imposing a legal obligation on a Contracting State to a resident extend to the residents of the other Contracting State, the benefit of any treatment, preference or privilege which may be accorded to any other State shallor its residents by virtue of the formation of a customs union, for the purpose economic union, a free trade area or by virtue of determining the taxable profits of such enterpriseany regional or sub-regional arrangement relating wholly or mainly to taxation, be deductible under the same conditions as if they had been paid to a resident of which the first-mentioned State. Similarly, any debts State may be a party pursuant to the practice of an enterprise of a either 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, 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 that taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) The provisions of . In this Article shall apply only 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, 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 the Contracting States. (2) The taxation on of 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) Except where the provisions of paragraph 1 (1) of Article 9, paragraph 7 (7) of Article 11 11, or paragraph 6 (6) of Article 12 12, apply, interest, royalties, fees for technical services 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-first- mentioned State. (4) Enterprises Exemptions 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 this Article shall shall, notwithstanding the provisions of Article 2, apply only 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, paragraph 6 of Article 12 or paragraph 6 of Article 12 13 apply, interest, 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. 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . 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. 6. 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 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 “nationals” 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. 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. (2) 4. 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) 5. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 5 of Article 12 apply, interest, royalties, fees for technical services 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-first- mentioned State. (4) 6. 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. (57. Nothing contained in this Article shall be construed as preventing Belgium: a) from taxing the total amount of the profits attributable to a permanent establishment in Belgium of a company which is a resident of Cyprus at the rate of tax provided by the Belgian law provided that this rate does not exceed the maximum rate applicable to the whole or a portion of the profits of companies which are residents of Belgium; b) from imposing the movable property prepayment on dividends derived from a holding which is effectively connected with a permanent establishment maintained in Belgium by a company which is a resident of Cyprus. 8. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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 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, are or may be subjected. This provision 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 Belgium 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 State than the taxation levied on enterprises of that other State carrying on the same activities. 3. This provision The provisions of paragraphs 1 and 2 shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs reliefs, and reductions for taxation purposes on account of civil status or family responsibilities which that it grants to its own residents. (3) 4. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 7 of Article 11 or paragraph 6 of Article 11 (Interest), or paragraph 4 of Article 12 (Royalties) apply, interest, royalties, fees for technical services 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 an enterprise a resident of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of such enterprisethe first-mentioned resident, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. (4) 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 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. 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 (5) Dividends). 7. The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply only 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. (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 residentsactivities in similar circumstances. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 8 or 9 of Article 11, paragraph 6 or 7 of Article 11 12, or paragraph 6 4 or 5 of Article 12 20 of this Convention apply, interest, royalties, fees for technical services royalties 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. 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State in similar circumstances are or may be subjected. 5. Nothing contained in this Article shall be construed as obliging a Contracting State to grant to individuals who are residents of the other Contracting State any of the personal allowances, reliefs and reductions for tax purposes which are granted to individuals so resident. 6. This Article shall not apply to any provision of the laws of a Contracting State which: (5a) is designed to prevent the avoidance or evasion of taxes; (b) does not permit the deferral of tax arising on the transfer of an asset where the subsequent transfer of the asset by the transferee would be beyond the taxing jurisdiction of the Contracting State under its laws; (c) provides for consolidation of group entities for treatment as a single entity for tax purposes provided that Australian resident companies that are owned directly or indirectly by residents of the United Kingdom can access such consolidation treatment on the same terms and conditions as other Australian resident companies; (d) provides deductions to eligible taxpayers for expenditure on research and development; or (e) is otherwise agreed to be unaffected by this Article in an Exchange of Notes between the Government of Australia and the Government of the United Kingdom. 7. The provisions of this Article shall apply only 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 obligation thereto related that is other not required or more burdensome than the taxation and connected requirements related obligations to which nationals of that other State in the same circumstances, in particular with respect to residence, circumstances are or may be subjected, especially in terms of residence. (2) The taxation . Taxation levied on a permanent establishment which establishments such as an enterprise of a Contracting State has may maintain in the other Contracting State shall not be less favourably levied favorable 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 allowancestax deductions, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services royalty payments or 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. SimilarlyBy the same token, any debts of liabilities assumed by an enterprise of a Contracting State with respect to a resident of the other Contracting State shall, shall be deductible for the purpose of determining the taxable capital subject to tax of such enterprise, be deductible company under the same conditions as if they such liabilities had been contracted assumed in regard to a resident of the first-mentioned State. (4) . Enterprises of a Contracting State, the whose 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 State to any taxation or any requirement connected therewith which obligation thereto related that is not required of other similar enterprises of this State or that is more burdensome than the taxation and connected requirements related obligations to which other similar these enterprises of the first-mentioned State are or may be subjected. (5) . The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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 term "nationals" means: (2a) 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. 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) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 6 of Article 11 11, or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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-first- mentioned State. (4) 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. (5) 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only to the taxes which are the subject of this Agreementevery kind and description.

NON-DISCRIMINATION. (1) . Nationals of a Contracting State, including the State itself or local authorities thereof, 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, including that State itself or local authorities thereof, 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 States. (2) . The taxation on 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 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 relieves and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 5 of Article 11 11, or paragraph 6 5 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-first- mentioned State are or may be subjected. (5) 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, 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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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 are or may be subjected nationals of that other State who are in the same circumstances, situation and in particular with respect from the point of view of the residence. (2) Stateless persons who are residents of a Contracting State shall not be subjected in either Contracting State to residence, any taxation or any requirement connected therewith which is other or more burdensome than those which are or may be subjectedsubjected national state of the State concerned are in the same situation. (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 less favorably than the taxation levied on imposition of 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 tax based on account of civil status or family responsibilities which it grants to its own residentsresidents state . (34) Except where Enterprises of a Contracting State, the capital of which is wholly or in part, directly or indirectly owned or controlled by one or more residents of the other Contracting State shall be subjected in the first-mentioned Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than are or may be subjected other similar enterprises of that first State. (5) Unless the provisions of paragraph 1 of Article 99 , Article 11 , paragraph 7 of 7, or Article 11 or 12 , paragraph 6 of Article 12 shall apply, interest, royalties, fees for technical services 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 enterpriseenterprise , 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 first State. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) 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, circumstances are or may be subjected, especially in terms of residence. (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. This provision shall may not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. SimilarlyAccordingly, any debts of an enterprise liabilities assumed by a company of a Contracting State with respect to a resident of the other Contracting State shall, for the purpose of shall be deductible in determining the taxable capital that is subject to tax of such enterprise, be deductible company under the same conditions as if they such liabilities had been contracted assumed with respect to a resident of the first-mentioned State. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, 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 this Article shall shall, notwithstanding the provisions of Article 2, apply only 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. (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. This provision Nothing in 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 that it grants to its own residents. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 6 of Article 11 or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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. Similarly, 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 with a resident of the first-mentioned State. (4) Enterprises 5. Companies which 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 is other or more burdensome than the taxation and connected requirements to which other similar enterprises companies which are residents of the first-mentioned State State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of a third State, are or may be subjected. (5) The provisions of 6. In this Article shall apply only to Article, the term "taxation" means taxes which that 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, circumstances are or may be subjected. (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. This provision 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 higher than that imposed on the profits of a similar enterprise 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 contained in this Article shall be construed as obliging a Contracting State to grant to residents of the other Contracting persons not resident in that State any personal allowances, reliefs reliefs, reductions and reductions deductions for taxation purposes on account of civil status or family responsibilities which it grants are by law available only to its own residentspersons who are so resident. (3) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, 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 State4. 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. (4) 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 that first-mentioned State are or may be subjectedsubjected in the same circumstances. (5) . The provisions of paragraphs 2 and 4 of this Article shall not apply only 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. 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, 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) . 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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or 11, paragraph 6 of Article 12 or paragraph 3 of Article 21 apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-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 only to the taxes which are the subject referred to in Article 2 of this AgreementConvention.

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, circumstances in particular with respect to residence, are or may be subjected. (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 tax purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 8 of Article 12 12, apply, interest, royalties, royalties and 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. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the that first-mentioned State are or may be subjected. (5) The provisions of . In this Article shall apply only 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) . The taxation on a permanent establishment or on a fixed base which an enterprise a resident 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 residents of that other State carrying on the same activities. 3. This provision Nothing in 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. (3) 4. 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. 5. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 of this Agreement, apply, interest, royalties, fees for technical services 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. (4) 6. 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) 7. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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. (2) . The taxation on of 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, unless they are enterprises of the socialized sector of the economy. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 6 of Article 11 11, or paragraph 6 of Article 12 of this Agreement apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-first- mentioned State are or may be subjectedsubjected unless they are enterprises of the socialized sector of the economy. (5) . The provisions of this Article shall apply only to the taxes which are the subject referred to in Article 2 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, circumstances in particular with respect to residence, are or may be subjected. (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 tax purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 8 of Article 12 12, apply, interest, royalties, royalties and 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. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-that first- mentioned State are or may be subjected. (5) The provisions of . In this Article shall apply only Article, the term "taxation" means taxes to the taxes which are the subject of this AgreementAgreement applies.

NON-DISCRIMINATION. (1) Nationals . The nationals of a Contracting State State, whether they are residents of one of the Contracting States or not, 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. (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 charges which it grants to its own residents. (3) Except where . With the provisions exception of paragraph 1 of the cases referred to in Article 9, Article 11, paragraph 7 of 4 and Article 11 or 12, paragraph 6 of Article 12 apply4, interest, royalties, fees for technical services royalties and other disbursements paid charges which an enterprise of a Contracting State pays to a resident of the other Contracting State may be deducted in calculating the taxable profits of such an enterprise under the same conditions as payments made to a resident of the first-mentioned State. Correspondingly, debts owed by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining may be deducted in calculating the taxable profits capital of such enterprise, be deductible enterprise under the same conditions as if they had been paid debts owed to a persons 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 in the first-mentioned State. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned 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. (5) The provisions of . In this Article shall apply only to the term "taxation" means 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. (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. This provision Nothing in 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. (3) 4. Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 7 6 of Article 11 or (Interest), paragraph 6 of Article 12 (Royalties) or paragraph 3 of Article 22 (Other Income) apply, interest, royalties, fees for technical services 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. (4) 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. (5) 6. The provisions of this Article shall apply only to the taxes which are the subject referred to in Article 2 (Taxes Covered) 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 especially with respect to residence, are or may be subjected. (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 tax purposes on account of civil status or family responsibilities which it grants to its own residents. (3) Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11, or paragraph 7 of Article 11 or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services and other disbursements dis­ bursements 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. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlledcon­ trolled, 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 In this Article shall apply only 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 of this Agreement apply, interestincome from debts claims, royalties, technical 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. 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-first mentioned State. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-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 its own individuals so resident. 6. 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 favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.Contracting (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or 11, paragraph 6 of Article 12 12, paragraph 4 of Article 14, or paragraph 3 of Article 21 apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-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 this Article shall shall, notwithstanding the provisions of Article 2, apply only 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 State, in the same circumstances, in particular with respect to residence, are or may be subjected. (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) Except where the provisions of paragraph 1 (1) of Article 9, paragraph 7 (6) or (7) of Article 11 11, or paragraph 6 (6) or (7) of Article 12 of this Agreement apply, interest, royalties, fees for technical services 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. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-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) 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 own nationals. (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 apply only to the taxes which are the subject of this Agreement.

NON-DISCRIMINATION. (1) . Nationals of a Contracting State State, whether or not they are residents of one of the Contracting States, 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 State in the same circumstances are or may be subjected. In particular, the nationals of a Contracting State who are subject to tax in the other Contracting State shall be granted the same exemptions, basic abatements, deductions and reductions for taxation purposes on account of family responsibilities which are granted to nationals of the other Contracting State in the same circumstances, in particular with respect to residence, are or may be subjected. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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 residents 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-first- mentioned State. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned 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. (5) . The provisions of term "taxation" in this Article shall apply only to the means taxes which are the subject of this Agreementany nature or description.

NON-DISCRIMINATION. (1) Nationals . Individuals who are nationals of a Contracting State and residents of the other Contracting State shall not be subjected in the that 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 individuals who are nationals and residents of that other State in the same circumstances, in particular with respect to residence, circumstances are or may be subjected. (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 reliefs, and reductions for taxation purposes on account of civil status or family responsibilities which that it grants to its own residents. The provisions of this paragraph shall not prevent the application by either Contracting State of the taxes described in paragraph 7 of Article 10 (Dividends). (3a) Except where the provisions of paragraph 1 of Article 99 (Associated Enterprises), paragraph 6 of Article 11 (Interest), or paragraph 7 of Article 11 or paragraph 6 of Article 12 (Royalties) apply, interest, 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 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. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose purposes 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. (b) Nothing in this Convention shall prevent the application of Article 212 of the French tax code (code general des impots) as it may be amended from time to time without changing the general principle thereof, or of any substantially similar provisions which may be enacted in addition to or in substitution for that provision (including provisions substantially similar to those applicable in the other Contracting State), to the extent that such application is consistent with the principles of paragraph 1 of Article 9 (Associated Enterprises). 4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . The provisions of this Article shall shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply only to taxes of every kind and description imposed by a Contracting State or a political subdivision (in the taxes which are case of the subject of this AgreementUnited States) 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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-first- mentioned State. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . 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. 6. 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, 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) any individual possessing the nationality of a Contracting State; b) any legal entity, partnership or association deriving its 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 favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) 4. Except where the provisions of paragraph 1 of Article 9, of paragraph 7 of Article 11 11, or paragraph 6 of Article 12 12, apply, interest, royalties, fees for technical services 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-first- mentioned State. (4) 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. (5) 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 4 or 5 of Article 11 11, paragraph 4 or paragraph 6 5 of Article 12 12, or paragraphs 4 or 5 of Article 20 apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) The provisions of . Nothing contained in this Article shall apply only be construed as obliging either Contracting State to grant to individuals not resident in that State any of the taxes personal allowances, reliefs and reductions for tax purposes which are the subject of this Agreementgranted to individuals so resident or to its nationals.

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 circumstances 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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 8 of Article 11 11, or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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 owed by 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) . The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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. (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) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, 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. 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. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-first mentioned State are or may be subjected. (5) The 4. Except where the provisions of paragraph 1 of Article 9, paragraph 6 of Article 11, or paragraph 6 of Article 12 apply, interest, royalty 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 subject to paragraph 3 of Article 7, under the same conditions as if they had been paid to a resident of the first- mentioned State. 5. In this Article shall apply only 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, 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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 4 of Article 11 11, or paragraph 6 4 of Article 12 12, apply, interest, royalties, fees for technical services 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned 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. (5) . The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only to taxes of every kind and description. 6. However, the taxes which are provisions mentioned in the subject previous paragraphs of this AgreementArticle will not limit the application of the domestic provisions for the prevention of the fiscal evasion and tax avoidance. This provision shall in any case include the limitations of the deduction of expenses and other negative elements deriving from transactions between enterprises of a Contracting State and enterprises situated in the other 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 Contracting State in the same circumstances, in particular with respect to residence, are or may be subjected. 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. Stateless persons who are residents 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. (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 Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activities. This provision The provisions of this paragraph 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) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or 11, paragraph 6 of Article 12 or paragraph 3 of Article 21 apply, interest, royalties, fees for technical services 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. (4) 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-first- mentioned Contracting State are or may be subjected. (5) 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only 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. (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) Except where the provisions of paragraph 1 (1) of Article 9, paragraph 7 (4) or (5) of Article 11 11, paragraph (6) or (7) of Article 12, or paragraph 6 (3) or (4) of Article 12 21 of this Agreement apply, interest, royalties, fees for technical services 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-first mentioned State. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) Nothing 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 its own individuals so resident. (6) 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. (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. This provision Nothing contained in this Article shall not be construed as obliging a either Contracting State to grant to residents individuals not resident in that State any of the other Contracting State any personal allowances, reliefs and reductions for taxation tax purposes on account of civil status which are granted to individuals so resident or family responsibilities which it grants to its own residentsnationals. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 10, paragraphs 4 or paragraph 6 5 of Article 12 11, paragraphs 4 or 5 of Article 12, or paragraphs 4 or 5 of Article 20 apply, interest, royalties, fees for technical services 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. (4) 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. (5) 6. The provisions of this Article shall apply only to the taxes which are the subject of this AgreementConvention.

NON-DISCRIMINATION. (1) . Nationals of a Contracting State one of the States 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 the nationals of either of the States even though they are not residents of one or both of the States. (2) . The taxation on a permanent establishment which an enterprise of a Contracting State one of the States 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 one of the States to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services royalties and other disbursements paid by an enterprise of a Contracting State one of the States 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. 4. Similarly, any debts Enterprises of an enterprise of a Contracting State to a resident one 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. (4) Enterprises of a Contracting StateStates, 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 this Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind and description. 6. The contributions made in a year with respect to services rendered in that year and paid by or on behalf of an individual residing in one of the States or who is temporarily staying in that State, to a pension plan recognized for tax purposes in the other State, shall apply only be treated during a period not exceeding a total of 60 months in the same manner for tax purposes in the first-mentioned State as a contribution paid to a pension plan recognized for tax purposes in that first-mentioned State, provided that: a) that individual is required to make contributions to the taxes which are pension plan by reason of his employment contract; b) that individual made contributions to the subject pension fund before being a resident of this Agreementor temporarily staying in the first-mentioned State; and c) the competent authority of the first-mentioned State agrees that the pension plan is equivalent to a pension plan recognized for tax purposes by that 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 term “national” means: (2i) all individuals possessing the nationality of a Contracting State; (ii) 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 favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) 4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 11, or paragraph 4 of Article 12, apply, interest, royalties, fees for technical services 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. SimilarlyIn the same manner, any the 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 with a resident of the first-mentioned State. (4) 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. (5) 6. The provisions of this Article shall shall, notwithstanding the provisions of Article 2, apply only to the taxes which are the subject of this Agreementany 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 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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 or Article 11, paragraph 6 of Article 11 12, or paragraph 6 of Article 12 21 apply, interest, royalties, fees for technical services 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. 4. Similarly, any debts The provisions of an enterprise of a Contracting State this Article shall not be construed to a resident of prevent Barbados from applying its tax on branch profits at the other Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be deductible rate specified under the same conditions as if they had been contracted to a resident of the first-mentioned StateIncome Tax Act. (4) 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. (5) The provisions of this 6. This Article shall apply only 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. (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) Except where the provisions of paragraph 1 of Article 9, paragraph 7 (7) of Article 11 or 11, paragraph 6 (6) of Article 12 or paragraph (6) of Article 13 of this Convention apply, interest, royalties, fees for technical services 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. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (5) The provisions of Nothing contained in this Article shall apply only be construed: (a) 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 (b) as affecting the provisions of the Pakistan law providing for a higher allowance or rebate of super-tax to those companies which make the prescribed arrangements for the declaration and payment of dividends. (6) In this Article the term "taxation" means the taxes to which are the subject of this AgreementConvention 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, circumstances are or may be subjected. (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) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, 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. 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. (4) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. (4. Except where the provisions of paragraph 1 of Article 9, paragraph 6 of Article 11, or paragraph 6 of Article 12 apply, interest, royalty 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 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, connnected 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. (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. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 or paragraph 6 of Article 12 apply, interest, 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. 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. (4) 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. (4. The provisions of paragraphs 2 and 3 of this Article shall not apply to the Vietnamese profit remittance tax, other than the tax referred to in paragraph 2 of Article 10, and the Vietnamese taxation in respect of agricultural production activities. 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. 6. 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. (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) . Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11 11, or paragraph 6 of Article 12 apply, interest, royalties, fees for technical services 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-first mentioned State. (4) . The provisions of this Article shall not be construed to prevent Barbados from applying its tax on branch profits at the rate specified under the Income Tax Act. 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. (5) The provisions of this 6. This Article shall apply only 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 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, are or may be subjected.and (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 levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. (3) . Except where the provisions of the second sentence of paragraph 5 of Article 7 (Business Profits), paragraph 1 of Article 99 (Associated Enterprises), paragraph 9 of Article 10 (Dividends), paragraphs 4 and 7 of Article 11 or paragraph 6 (Interest), paragraphs 4 and 5 of Article 12 (Royalties), or paragraphs 3 and 4 of Article 22 (Other Income) of this Convention apply, interest, royalties, fees for technical services 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 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. (4) . Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which 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) The provisions of . Nothing in this Article shall apply only be construed as obliging either Contracting State to grant to individuals not resident in that State any of the taxes personal allowances, reliefs and reductions for tax purposes which are the subject granted to individuals so resident or to its nationals. 6. Nothing in this Article shall be construed as preventing either Contracting State from imposing a tax as described in paragraph 7 of this Agreement.Article 10 (Dividends)