Double taxation avoidance: India-Brazil treaty allocates taxing rights, defines residence and permanent establishment, and provides information exchange mechanisms. Convention creates a bilateral framework under section 90 to avoid double taxation and prevent fiscal evasion between India and Brazil, applying to residents and specified national taxes; it defines residence and key terms, allocates taxing rights across categories of income (including business profits, immovable property, dividends, interest, royalties and capital gains), sets permanent establishment and agency rules, prescribes withholding ceilings for certain passive incomes, establishes elimination of double taxation methods, a mutual agreement procedure, and an exchange of information clause subject to confidentiality and domestic law limits.