Avoidance of double taxation framework allocating taxing rights and credit relief between India and Thailand under defined residence and PE rules. Convention provides a bilateral framework for avoidance of double taxation and prevention of fiscal evasion between India and Thailand, applying to residents and taxes on income of each State. It defines core terms, prescribes residence tie-breakers, and details permanent establishment criteria (including a 183-day service/construction threshold and specified exclusions). The treaty allocates taxing rights across income categories (business profits, immovable property, dividends, interest, royalties, capital gains, personal services) and requires the residence State to provide credit for tax paid in the source State subject to statutory limits. It also establishes non-discrimination, a Mutual Agreement Procedure, and an exchange of information regime with secrecy safeguards.