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India-Ireland DTAA protection for aircraft dry-lease rentals cannot be denied under the Multilateral Instrument's Principal Purpose Test unless Articles 6 and 7 have been specifically notified under section 90(1); valid tax residency, substantive commercial activity and cross-border leasing alone do not establish impermissible treaty shopping. Article 8(1) covers profits from operating or renting aircraft in international traffic, allocating the rentals solely to Ireland and prevailing over general business-profits provisions. Aircraft presence and ordinary inspection, maintenance and repossession rights do not create a fixed-place permanent establishment. Where ownership, return obligations and repossession rights remain with the lessor, dry leases are operating leases rather than interest-bearing finance leases.
India-Ireland DTAA protection for aircraft dry-lease rentals cannot be denied under the Multilateral Instrument's Principal Purpose Test unless Articles 6 and 7 have been specifically notified under section 90(1); valid tax residency, substantive commercial activity and cross-border leasing alone do not establish impermissible treaty shopping. Article 8(1) covers profits from operating or renting aircraft in international traffic, allocating the rentals solely to Ireland and prevailing over general business-profits provisions. Aircraft presence and ordinary inspection, maintenance and repossession rights do not create a fixed-place permanent establishment. Where ownership, return obligations and repossession rights remain with the lessor, dry leases are operating leases rather than interest-bearing finance leases.
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