Double taxation treaty allocates taxing rights between India and Malta, limiting source state taxation of dividends, interest and royalties. The Agreement sets a bilateral double taxation framework allocating taxing rights by income categories and prescribes elimination methods: resident taxation subject to source state taxing of immovable property, business profits attributable to a permanent establishment, exclusive taxation for international shipping and air transport profits, and situs/residence rules for gains. It defines resident, permanent establishment (including construction, substantial equipment and dependent agents with contracting authority) and provides withholding ceilings for dividends, interest, royalties and technical fees with beneficial owner and effective connection exceptions, together with mutual agreement, exchange of information and non discrimination procedures.