Double taxation avoidance applies to residents of India and Israel under a treaty now given effect within domestic law. The India-Israel Convention for the avoidance of double taxation and prevention of fiscal evasion has been directed to be given effect within India under domestic tax implementation powers after the Convention entered into force. Article 1 sets the personal scope, providing that the Convention applies to persons who are residents of one or both contracting States, thereby determining treaty application based on residence for taxes on income and capital.