Double taxation avoidance applies to residents of one or both contracting states, defining treaty scope and application.

The Central Government directs that the India-South Africa Agreement for avoidance of double taxation and prevention of fiscal evasion be given effect in India; the Agreement's personal scope provides that it applies to persons who are residents of one or both Contracting States, thereby defining the class of taxpayers to which the treaty's relief and anti-evasion provisions apply.

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