Taxation of international transport profits: resident enterprises taxed only in their state for transport operations and related interest. Profits from operation of ships, aircraft or land vehicles in international traffic by an enterprise resident and effectively managed in a Contracting ... Summary
Taxation of international transport profits: resident enterprises taxed only in their state for transport operations and related interest.
Profits from operation of ships, aircraft or land vehicles in international traffic by an enterprise resident and effectively managed in a Contracting State are taxable only in that State; this covers participation in pools, joint businesses and international operating agencies, and treats interest connected with such operation as business profits. "Operation of aircraft" includes carriage of passengers, mail, livestock or goods, ticket sales for others and incidental leasing; "operation of ships" includes container use, maintenance or rental and full or bareboat ship rentals when used in international traffic.
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