Taxation of international shipping and air transport: profits taxable only in the enterprise's contracting state under specified conditions. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; management aboard a ship is deemed located in the state of the ship's home harbor or the operator's residence if no home harbor exists. Container income incidental to such operations is taxable only in the enterprise's Contracting State unless containers are used solely within the other Contracting State. Interest integral to international transport operations is treated as transport profits and Article 11 does not apply. The exclusive taxation rule covers participation in pools, joint businesses, and 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.
Taxation of international shipping and air transport: profits taxable only in the enterprise's contracting state under specified conditions.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; management aboard a ship is deemed located in the state of the ship's home harbor or the operator's residence if no home harbor exists. Container income incidental to such operations is taxable only in the enterprise's Contracting State unless containers are used solely within the other Contracting State. Interest integral to international transport operations is treated as transport profits and Article 11 does not apply. The exclusive taxation rule covers participation in pools, joint businesses, and international operating agencies.
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