Double taxation avoidance treaty allocates taxing rights and provides relief mechanisms for cross-border income and capital. The Convention allocates taxing rights for income and capital between the Contracting States, applies to residents of one or both States, and establishes definitions for residence and related terms. It defines permanent establishment with inclusions, exclusions and thresholds, prescribes that business profits are taxable in the resident State unless attributable to a permanent establishment in the other State, and requires arm's-length attribution for permanent establishment profits with limits on intercompany deductions. The treaty caps source withholding on dividends, interest and royalties subject to beneficial owner and connectivity exceptions and prescribes domestic relief mechanisms to eliminate double taxation.