Shipping and air transport profits taxed exclusively in the resident State, including container income and integral interest. Profits from operating ships or aircraft in international traffic by a resident are taxable only in that Contracting State; this exclusive taxing right also covers container use, maintenance or rental for international transport unless containers are used solely within the other State. Interest directly connected and integral to such operations is treated as operational profits and excluded from Article 11, and profits from participation in pools, joint businesses or international operating agencies are similarly subject to the exclusive taxing rule.
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.
Shipping and air transport profits taxed exclusively in the resident State, including container income and integral interest.
Profits from operating ships or aircraft in international traffic by a resident are taxable only in that Contracting State; this exclusive taxing right also covers container use, maintenance or rental for international transport unless containers are used solely within the other State. Interest directly connected and integral to such operations is treated as operational profits and excluded from Article 11, and profits from participation in pools, joint businesses or international operating agencies are similarly subject to the exclusive taxing rule.
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