Avoidance of double taxation: treaty allocates taxing rights, limits source taxation and mandates mutual agreement and information exchange. Bilateral tax treaty allocates taxing rights between India and Czechoslovakia, applies to residents and specified national taxes, and sets residency tie breaker rules and a definition of permanent establishment. It prescribes attribution of business profits to permanent establishments on an arm's length basis, limits source taxation of dividends, interest, royalties and fees for technical services for beneficial owners, and governs taxation of immovable property, capital gains and personal services. The treaty provides elimination of double taxation via exemption and credit rules, non discrimination, mutual agreement procedure, and exchange of information subject to confidentiality and legal limits.