Avoidance of double taxation: treaty allocates taxing rights and prescribes PE-based profit attribution and relief mechanisms. The Agreement allocates taxing rights between India and Canada to avoid double taxation and prevent fiscal evasion by applying to residents and taxes on income, defining key terms and residency tie-breakers, and prescribing permanent establishment criteria and profit attribution on an arm's-length basis. It sets source-state withholding limits for dividends, interest and royalties/technical fees, provides rules for business profits, immovable property, capital gains, and various personal services, and establishes mechanisms for elimination of double taxation, mutual agreement procedures, exchange of information, non-discrimination, and entry into force and termination rules.