Avoidance of Double Taxation: treaty limits source taxation on dividends, interest and royalties and defines residency and PE rules. The Convention, given effect under the domestic enabling provision, allocates taxing rights and prescribes rules to eliminate double taxation for residents by defining residence and permanent establishment, attributing PE profits as a separate enterprise, and limiting source taxation of dividends, interest, royalties and technical service fees (with specified ceilings for beneficial owners). It establishes a mutual agreement procedure, exchange of information with confidentiality safeguards, non discrimination protections, and a Protocol clarifying profit attribution for construction projects and interaction with other bilateral agreements.