Double taxation treaty personal scope applies to residents of India or Brazil, while preserving domestic taxation limits. The India-Brazil Convention on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income is given effect in India through notification under the Income-tax Act and the Companies (Profits) Surtax Act. Article 1 applies the Convention to persons who are residents of one or both Contracting States and preserves a Contracting State's taxation of its own residents, except for specified treaty benefits under the listed articles.