Virtually all non-discrimination articles confer on enterprises owned by non-residents rights that parallel those granted to nationals. Article 24(4) of the Japan-UK double tax treaty exemplifies this rule:

‘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 to any taxation or any requirement in connection therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first state may be subjected.’

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