Profits from international shipping and air transport are taxable only in the State of operation, with exclusive taxing rights. Profits of an enterprise of a Contracting State from operating ships or aircraft in international traffic are taxable only in that State, including profits from use, maintenance or rental of containers used in international carriage, and profits from participation in pools, joint businesses or international operating agencies. Where effective management is aboard a ship, it is treated as located in the State of the ship's home harbour or, if none, the State of the operator's residence. Interest directly connected and integral to such operations is treated as operational profits and excluded from separate interest rules.
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.
Profits from international shipping and air transport are taxable only in the State of operation, with exclusive taxing rights.
Profits of an enterprise of a Contracting State from operating ships or aircraft in international traffic are taxable only in that State, including profits from use, maintenance or rental of containers used in international carriage, and profits from participation in pools, joint businesses or international operating agencies. Where effective management is aboard a ship, it is treated as located in the State of the ship's home harbour or, if none, the State of the operator's residence. Interest directly connected and integral to such operations is treated as operational profits and excluded from separate interest rules.
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