In addition, the UN Model Convention embodies the idea that it would be appropriate for the country of residence to extend a double taxation exemption measure, either through foreign tax credits or exemptions, as in the OECD Model Convention. International double taxation has a negative impact on trade and services, as well as on the movement of capital and people. The taxation of the same income by two or more countries would represent a prohibitive burden on the taxpayer. The domestic laws of most countries, including India, mitigate this difficulty by granting unilateral relief to such double-taxation income (section 91 of the Income Tax Act). However, since this is not a satisfactory solution, given the differences between the rules for determining sources of income in different countries, tax treaties attempt to eliminate tax barriers that impede trade and services, as well as the movement of capital and persons between the countries concerned. It helps to improve the overall investment climate. . . .