Avoidance of double taxation: treaty allocates taxing rights, limits source state withholding tax and provides mutual agreement procedures. The India-USSR agreement provides a bilateral regime for avoidance of double taxation, covering residents and specified taxes, and defines residence, permanent establishment and attribution of profits. It allocates taxing rights for business profits, immovable property, shipping and air transport, and limits source state withholding on dividends, interest and royalties subject to exceptions. The treaty prescribes non discrimination, elimination of double taxation through domestic relief, a mutual agreement procedure for resolving disputes, exchange of information with confidentiality safeguards, and rules on entry into force and termination.