Double taxation avoidance treaty applies to residents, operative after entry into force and given effect domestically under executive power. Double taxation avoidance and prevention of fiscal evasion are implemented between India and Slovenia by a Convention that entered into force upon exchange of instruments of ratification, and the Central Government, under Section 90 of the Income-tax Act, 1961, has directed that all provisions of the Convention be given effect in India; the Convention applies to persons who are residents of one or both Contracting States.