According to: Java Revisited
Resources included by include directive are loaded during jsp translation time, while resources included by include action are loaded during request time.
Any change on included resources will not be visible in case of include directive until jsp file compiles again. While in case of include action, any change in included resource will be visible in the next request.
Include directive is static import, while include action is dynamic import.
Include directive uses file attribute to specify resources to be included while include action uses page attribute for the same purpose.