Taxation of shipping and air transport: exclusive residence taxation for profits from international operations and related container use. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State of residence. Income from use, maintenance or rental of containers incidental to such international operations is similarly taxable only in the resident State unless the containers are used solely within the other Contracting State. Interest integral to the operation of ships or aircraft is treated as operational profits and excluded from separate interest provisions. The exclusive residence taxation rule also covers participation in pools, joint businesses and international operating agencies related to international transport.
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 shipping and air transport: exclusive residence taxation for profits from international operations and related container use.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State of residence. Income from use, maintenance or rental of containers incidental to such international operations is similarly taxable only in the resident State unless the containers are used solely within the other Contracting State. Interest integral to the operation of ships or aircraft is treated as operational profits and excluded from separate interest provisions. The exclusive residence taxation rule also covers participation in pools, joint businesses and international operating agencies related to international transport.
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