Double taxation avoidance treaty allocates taxing rights and relief, with permanent establishment rules, withholding limits, and information exchange. Bilateral Convention to avoid double taxation and prevent fiscal evasion: applies to residents, specifies covered taxes, and defines key terms. Residency tie breakers use centre of vital interests for individuals and place of effective management for entities. Permanent establishment rules delineate attributable activities, exclusions and agency tests; business profits attributable to a PE are to be computed as if the PE were a distinct enterprise, subject to deduction rules and methodological consistency. Articles fix taxing rights and withholding ceilings for dividends, interest and royalties, provide capital gains and personal services rules, prescribe elimination of double taxation by exemption or credit, non discrimination, mutual agreement procedures and exchange of information, and set entry into force and termination modalities.