Double tax avoidance scope: treaty applies to persons resident in one or both Contracting States and is given effect domestically. The Central Government has directed that the Convention between India and New Zealand for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income shall be given effect in India under section 90 of the Income-tax Act and section 24A of the Companies (Profits) Surtax Act. Article 1 provides that the Convention applies to persons who are residents of one or both Contracting States, establishing residency as the criterion for treaty applicability.