Article 8 - International Shipping and Air Transport

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....ovisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. [ Para 2 of Article 8 ] As per UN Model Tax Convention * Article 8 ( Alternative A ) * Article 8 (Alternative A) of the United Nations Model Convention reproduces Article 8 of the OECD Model Convention. * Article 8 ( Alternative B ) * ​Profits ....

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....percentage is to be established through bilateral negotiations.). [ Para 2 of Article 8( Alternative B ) ] * The provisions of paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. [ Para 3 of Article 8 (Alternative B) ] As per Indian Income tax Act, 1961 deal with according provision mentioned mentioned below *....