Avoidance of double taxation: treaty sets residence, permanent establishment rules and limits on withholding taxation between jurisdictions. Notification under section 90 gives effect in India to the India-Hong Kong Agreement avoiding double taxation and preventing fiscal evasion. The treaty applies to residents and taxes on income, defines residency and permanent establishment rules, allocates taxing rights for business profits, dividends, interest, royalties, technical fees and capital gains, prescribes withholding tax limits for beneficial owners subject to effective-connection exceptions, provides methods for elimination of double taxation, non-discrimination, mutual agreement and exchange-of-information mechanisms, and contains anti-abuse provisions and Protocol clarifications.