Avoidance of double taxation: treaty allocates taxing rights, sets permanent establishment rules and withholding limits. The Agreement provides a bilateral framework to avoid double taxation and prevent fiscal evasion between India and Switzerland, defining residence and tie breaker rules, the permanent establishment standard with specific inclusions and exclusions, and allocates taxing rights across income categories-including business profits, immovable property, dividends, interest, royalties, fees for included services and capital gains-while prescribing withholding rate ceilings, exceptions for effectively connected income, methods for elimination of double taxation, a mutual agreement procedure, and exchange of information with confidentiality safeguards.