Non-discrimination

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..... e in the same circumstances and under the same conditions are or may be subjected. This provision shall, notwithstanding the provisions of article 1, also apply to persons who are not residents of one or both of the Contracting States. 1 [ 2. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourabl .....

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..... d 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 tax .....

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