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        DTAA

        Article 8 - International Traffic

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        International traffic profits taxable in source state only, including integral investment interest and pools' prorated shares. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; interest on investments that are directly connected and integral to such operations is treated as profits from the operation and excluded from Article 11; and profits from participation in a pool, joint business, or international operating agency are taxable only to the extent attributable to the participant in proportion to its share.
                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.

                                International traffic profits taxable in source state only, including integral investment interest and pools' prorated shares.

                                Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; interest on investments that are directly connected and integral to such operations is treated as profits from the operation and excluded from Article 11; and profits from participation in a pool, joint business, or international operating agency are taxable only to the extent attributable to the participant in proportion to its share.


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