1. Nationals of a Contracting State shall not be subjected in the other  Contracting State to any taxation or any requirement connected therewith, which is  other or more burdensome than the taxation and connected requirements to which  nationals of that other State in the same circumstances, in particular with respect to  residence, are or may be subjected. This provision shall, notwithstanding the  provisions of Article 1, also apply to persons who are not residents of one or both of  the Contracting States. 

2. Stateless persons who are residents of a Contracting State shall not be  subjected in either Contracting State to any taxation or any requirement connected  therewith which is other or more burdensome than the taxation and connected  requirements to which nationals of the State concerned in the same circumstances 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 then the taxation levied on enterprises of that other State  carrying on the same activities.

4. Except where the provisions of Article 9, paragraph 7 of Article 11, or paragraph 4 of Article 12, apply, interest, royalties and other disbursements paid by  an enterprise of a Contracting State to a resident of the other Contracting State shall,  for the purpose of determining the taxable profits of such enterprise, be deductible  under the same conditions as if they had been paid to a resident of the first mentioned State. Similarly, any debts of an enterprise of a Contracting State to a  resident of the other Contracting State shall, for the purpose of determining the  taxable capital of such enterprise, be deductible under the same conditions as if they  had been contracted to a resident of the first-mentioned State. 

5. Enterprises of a Contracting State, the capital of which is wholly or partly  owned or controlled, directly or indirectly, by one or more residents of the other  Contracting State, shall not be subjected in the first-mentioned State to any taxation  or any requirement connected therewith which is other or more burdensome than the  taxation and connected requirements to which other similar enterprises of the first mentioned State are or may be subjected. 

6. The provisions of this Article shall 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, notwithstanding the provisions of  Article 2, apply to taxes of every kind and description.