Double taxation agreement limits source taxing rights and strengthens PE, information exchange and tax assistance mechanisms. Bilateral tax convention between India and the United Kingdom allocates taxing rights on income and capital gains, defines residents and taxable persons, and prescribes rules for permanent establishments, attribution of profits, and specific source taxing regimes for dividends, interest, royalties, employment and other income. It provides mechanisms for elimination of double taxation by credit, a mutual agreement procedure, non discrimination, and comprehensive administrative cooperation including exchange of information. A 2012 Protocol (effective 2013) amends definitions, dividends rules, deletes partnerships provisions, and adds tax examinations abroad, assistance in tax collection and a limitation of benefits rule.