Avoidance of double taxation treaty establishes taxing rights, PE rules, withholding limits and information exchange between India and Luxembourg. The India-Luxembourg Agreement provides a bilateral framework to eliminate double taxation and prevent fiscal evasion for taxes on income and capital, prescribes resident definitions and tie breaker rules, and defines permanent establishment with rules for profit attribution. It allocates taxing rights across income categories (dividends, interest, royalties, business profits, capital gains, personal services), establishes methods for elimination of double taxation, mutual agreement and exchange of information procedures, assistance in tax collection, and anti abuse and exclusion provisions; India directed effect from 1 April 2010.