Avoidance of double taxation: bilateral framework allocating taxing rights and PE rules between India and Austria. Bilateral Convention to avoid double taxation and prevent fiscal evasion on income taxes between India and Austria: applies to residents and specified taxes, defines residency and tie breakers, sets permanent establishment criteria with inclusions/exclusions and agency rules, allocates taxing rights for immovable property, business profits (attributable to PE on an arm's length basis), shipping/air transport, dividends, interest, royalties/fees and capital gains, prescribes methods for elimination of double taxation (exemption or credit), non discrimination, mutual agreement procedure, and exchange of information subject to secrecy and public policy exceptions; Protocol clarifies immovable property taxation, minimum head office deduction, partnership treatment, permissible PE tax rate differentials and data protection safeguards.