On 12 January 2024, the Supreme Court of Pakistan issued an judgment concerning the scope of income covered by Article 8 (Shipping and Air Transport) of the 1980 tax treaty with Belgium and Article 8 (Profits From International Traffic) of the 1987 tax treaty with Denmark. The case involved two non-resident shipping companies incorporated in Belgium and Denmark (the respondents) that claimed treaty benefits under Article 8 of the respective treaties in respect of income derived from containe…