Double taxation avoidance: treaty allocates taxing rights and limits withholding taxes on cross-border income for residents. The Agreement allocates taxing rights between the Contracting States for residents, defines residence and tie-breaker rules, and sets a detailed permanent establishment concept with inclusions and exclusions. It prescribes taxation rules for immovable property, business profits (attributable to a PE on an arm's-length basis), international traffic, associated enterprises, capital gains, dividends, interest and royalties (with capped source withholding rates where the recipient is beneficial owner). Relief is provided by tax credits, and cooperation is enabled through mutual agreement, exchange of information and assistance in tax collection.