Taxation of international transport profits limited to the enterprise's residence territory, excluding other jurisdictions' taxation. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's territory; this includes profits from full charters and from use, maintenance or rental of containers and related equipment when incidental to international transport. Interest and investments integral and directly connected to such operations are treated as profits from the operation and are not subject to separate taxation under general provisions. The exclusive-taxation rule also applies to income from 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 transport profits limited to the enterprise's residence territory, excluding other jurisdictions' taxation.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's territory; this includes profits from full charters and from use, maintenance or rental of containers and related equipment when incidental to international transport. Interest and investments integral and directly connected to such operations are treated as profits from the operation and are not subject to separate taxation under general provisions. The exclusive-taxation rule also applies to income from participation in pools, joint businesses, and international operating agencies.
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