Shipping and air transport profits attract exclusive taxation in the enterprise's State, including income from pools and joint operators. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State, and this exclusive taxation also covers profits from participation in pools, joint businesses and international operating agencies related to such international transport activities.
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 attract exclusive taxation in the enterprise's State, including income from pools and joint operators.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State, and this exclusive taxation also covers profits from participation in pools, joint businesses and international operating agencies related to such international transport activities.
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