Double taxation avoidance: Treaty allocates taxing rights between contracting states and provides relief and exchange mechanisms. Notification implements the Agreement and Protocol under Section 90, applying treaty provisions from the fiscal year following entry into force; it identifies covered taxes, extends to substantially similar future taxes, and requires mutual notification of major tax-law changes. The treaty allocates taxing rights by income category, defines residency and permanent establishment rules and thresholds, limits source-state withholding on dividends, interest and royalties subject to effective-connection exceptions, and prescribes relief by residence-state tax credit. It establishes a mutual agreement procedure, an exchange of information regime with confidentiality safeguards, a limitation-of-benefits rule, and procedures for entry into force and termination.