Double taxation avoidance treaty framework allocating taxing rights and limiting source state withholding on passive income. Treaty provides rules for residence, defines permanent establishment including exclusions, and allocates taxing rights: business profits taxed only in residence unless a permanent establishment exists, immovable property income taxable at source, international traffic profits taxable only in residence, and withholding limits apply to dividends, interest and royalties when the recipient is beneficial owner. It prescribes elimination of double taxation by credit/deduction limited to tax attributable to income taxed in the other State, supplies non discrimination, mutual agreement and exchange of information procedures, assistance in tax collection, and a protocol denying benefits to entities substantially owned by non residents unless substantive business operations exist or competent authorities agree otherwise.