Taxation of international shipping and air transport profits limited to the enterprise's State of residence, with specific rules for management and containers. Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of residence; this exclusivity also covers participation in pools, joint businesses, and international operating agencies. Place of effective management aboard a ship is deemed in the State of the ship's home harbour or the operator's residence if no home harbour exists. Container use, maintenance or rental profits are taxable only in the resident State unless containers are used solely within the other State. Interest integral to such operations is treated as operational profits and not governed by the separate interest provision.
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.
Taxation of international shipping and air transport profits limited to the enterprise's State of residence, with specific rules for management and containers.
Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of residence; this exclusivity also covers participation in pools, joint businesses, and international operating agencies. Place of effective management aboard a ship is deemed in the State of the ship's home harbour or the operator's residence if no home harbour exists. Container use, maintenance or rental profits are taxable only in the resident State unless containers are used solely within the other State. Interest integral to such operations is treated as operational profits and not governed by the separate interest provision.
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