Withholding tax limits on cross border dividends, interest and royalties restricted under the treaty, with mutual relief mechanisms. Bilateral convention between India and the Russian Federation allocates taxing rights on income of residents, defines residency and permanent establishment rules, attributes business profits to permanent establishments on an arm's length basis, and prescribes source taxation regimes for dividends, interest, royalties and fees for technical services subject to limited source taxation and exemptions. It provides methods for elimination of double taxation, a mutual agreement procedure for disputes, exchange of information with confidentiality safeguards, a non discrimination rule, and protocol modifications addressing international transport, supervisory activities on projects and permissible rate differentials for permanent establishment taxation.