Double taxation avoidance: treaty allocates taxing rights, limits source taxation and provides MAP and information exchange mechanisms. Treaty between India and the Hungarian People's Republic applies to residents and taxes on income, defining residence and company concepts. Business profits are taxable in the residence State except where attributable to a permanent establishment in the other State; immovable property and specified capital gains may be taxed where situated. Dividends, interest, royalties and technical service fees may be taxed in source State subject to reduced source taxation where the recipient is beneficial owner and not effectively connected to a permanent establishment. Relief is provided by exemption or credit, supported by a mutual agreement procedure and exchange of information.