Double taxation treaty rules: source state withholding limits and PE based profit allocation between the two States. Convention between India and Namibia to avoid double taxation and prevent fiscal evasion on income and capital gains: it applies to residents, designates covered taxes and successor taxes, defines residence and permanent establishment, allocates taxing rights (immovable property, business profits attributable to a permanent establishment, shipping/air transport management based taxation), prescribes transfer pricing adjustment relief, caps withholding tax rates at 10% for dividends, interest, royalties and technical service fees (subject to connection with a permanent establishment), provides elimination of double taxation via credit or deduction, and establishes non discrimination, mutual agreement and information exchange mechanisms with specified entry into force and termination rules.