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A Russian airline subsidiary operating in Spain carries out ticket sales and passenger services. The DGT determines that these profits are covered under Article 8 of the Spanish-Russian Double Taxation Convention.
Question posed: Application of Article 8 of the Spain-Russia Double Taxation Convention to the activity of the branch.
Profits from the exploitation of aircraft in international traffic may only be taxed in the State of residence. According to the OECD Model, this includes activities directly linked or ancillary to international traffic operations, such as the sale of tickets by the company itself.
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