International traffic profits taxable only in the enterprise's State of residence; related container and integral interest income included. Profits derived by an enterprise from the operation of ships or aircraft in international traffic are taxable only in the enterprise's State of residence; this rule covers participation in pools, joint businesses and international operating agencies, and extends to incidental container use, while interest integral to such operations is treated as operational profits and not subject to the separate interest provisions of Article 11.
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 taxable only in the enterprise's State of residence; related container and integral interest income included.
Profits derived by an enterprise from the operation of ships or aircraft in international traffic are taxable only in the enterprise's State of residence; this rule covers participation in pools, joint businesses and international operating agencies, and extends to incidental container use, while interest integral to such operations is treated as operational profits and not subject to the separate interest provisions of Article 11.
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