International traffic profits: exclusive taxation in the enterprise's State of residence for operational, container and incidental interest income. Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's State of residence. This covers transportation of passengers, goods, mail or livestock; use or rental of containers and related equipment used in international carriage, except where containers are used solely within the other Contracting State; interest directly connected with and incidental to such operations, which is treated as operational profit and excluded from Article 11; and profits from participation in pools, joint businesses or international operating agencies.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
International traffic profits: exclusive taxation in the enterprise's State of residence for operational, container and incidental interest income.
Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's State of residence. This covers transportation of passengers, goods, mail or livestock; use or rental of containers and related equipment used in international carriage, except where containers are used solely within the other Contracting State; interest directly connected with and incidental to such operations, which is treated as operational profit and excluded from Article 11; and profits from participation in pools, joint businesses or international operating agencies.
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