Double taxation avoidance treaty allocates taxing rights, permanent establishment rules, withholding limits and mutual agreement procedures. Convention gives domestic effect to an agreement to avoid double taxation and prevent fiscal evasion, applying to residents and specified taxes on income and capital; it defines key terms and allocates taxing rights: immovable property is taxable in situs State; business profits are taxable in the resident State except profits attributable to a permanent establishment in the other State determined on an arm's-length separate enterprise basis; specific rules and limitations apply to dividends, interest, royalties and fees for technical services; capital gains, personal services, pensions, government remuneration, artists, students and teachers receive tailored sourcing and exemption rules; relief is by tax credit, mutual agreement procedure, information exchange and collection assistance; entry into force, confidentiality and termination provisions are included.