Double taxation agreement limits source state withholding on investment income and establishes PE, capital gains and information exchange rules. The Double Taxation Avoidance Agreement allocates taxing rights: business profits taxable in source only when a permanent establishment exists; aircraft operation profits taxable in the state of place of effective management; dividends, interest, royalties and technical fees taxable in both residence and source but subject to maximum source state rates; capital gains on share sales taxable in the source state. The Agreement further provides for exchange of information, assistance in tax collection and anti abuse provisions to restrict treaty benefits to residents.