Double taxation avoidance: treaty allocates taxing rights, defines permanent establishment and provides tax credit relief across jurisdictions. The Convention provides a bilateral framework to avoid double taxation and prevent fiscal evasion by defining taxes covered, resident status and tie breaker rules, and by allocating taxing rights: immovable property is taxed where situated; business profits are taxable in the residence State unless attributable to a permanent establishment in the source State, with profits attributed on an arm's length basis; dividends, interest, royalties and management fees may be taxed in the source State subject to specified maximum withholding and exceptions when effectively connected to a permanent establishment.