Tax treaty provisions on residence and permanent establishment limit double taxation and allocate cross-border taxing rights. The Agreement provides a bilateral framework to avoid double taxation and prevent fiscal evasion on income taxes, applying to residents of one or both Contracting States and to income taxes imposed by those States. It defines residence and permanent establishment, allocates taxing rights for categories of income (business profits, immovable property, dividends, interest, royalties, capital gains, personal services and other income), prescribes methods for elimination of double taxation by credit/deduction subject to limits, and establishes administrative cooperation mechanisms including mutual agreement, exchange of information and assistance in collection, together with non discrimination and limitation of benefits rules.