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 container detention charges (CDC), container service charges (CSC), and terminal handling charges (THC) from business operations in Pakistan. The benefits were claimed by...