The GATS and its MFN obligation came into effect before WTO Members were willing to completely eliminate discriminatory measures in services trade. The Agreement therefore had to strike a difficult balance between creating meaningful multilateral disciplines and accommodating discriminatory trade practices. The challenge to multilateral disciplines posed by the explicit departures from the MFN obligation, such as the exceptions for regional integration agreements and the MFN exemptions listed by Members, are widely recognized. However, the difficulties arising from less visible, implicit discrimination have not been adequately appreciated.