Double taxation avoidance: treaty rules on residence, permanent establishment and withholding govern cross border income allocation. Bilateral tax treaty between India and Georgia sets rules for residence, scope of taxes on income and capital, and permanent establishment criteria (including a 90 day construction/service rule). It allocates business profits to the residence State unless attributable to a PE, prescribes withholding limits for dividends, interest, royalties and technical fees with specified exemptions, provides methods for elimination of double taxation, and includes mutual agreement, exchange of information, non discrimination, limitation of benefits and tax collection assistance provisions; effective in India from 1 April 2012.