Double taxation avoidance treaty allocates cross-border taxing rights and provides credit relief, permanent establishment and information-exchange mechanisms. Convention allocates taxing rights between India and New Zealand for taxes on income, defines resident and permanent establishment, and confines business profits taxation to the State of residence except when an enterprise operates through a permanent establishment in the other State. It prescribes attribution of profits to such establishments, allows customary deductions, sets withholding limits on dividends, interest and royalties for beneficial owners, provides rules for personal and employment services, and mandates elimination of double taxation by crediting source-State tax; it also includes non-discrimination, mutual agreement and exchange-of-information provisions.