The most common prohibitions against tax discrimination found in bilateral treaties appear in art. 24 of the OECD Model, which contains six distinct basic principles:

(1)Nationals of a contracting state may not be subject to any taxation or any requirement connected therewith which is more burdensome than the other contracting state imposes upon its own nationals in the same circumstances. This prohibition applies notwithstanding the fact that the persons are not residents of one or both of the contracting states.

(2)Stateless persons who are residents of one contracting state are similarly to be protected from tax discrimination.

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