Taxation of international shipping and air transport profits confined to the enterprise's state, including containers, pools and consortium shares. Profits from operating ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State; the same rule applies to profits from use, maintenance or rental of containers and related equipment used for international transport, except where such equipment is used solely for transport within the other Contracting State. Interest integral to operations is treated as operational profits and pools, joint businesses and international operating agencies are covered; consortium profits apply proportionately to the Norwegian partner's share.
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 confined to the enterprise's state, including containers, pools and consortium shares.
Profits from operating ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State; the same rule applies to profits from use, maintenance or rental of containers and related equipment used for international transport, except where such equipment is used solely for transport within the other Contracting State. Interest integral to operations is treated as operational profits and pools, joint businesses and international operating agencies are covered; consortium profits apply proportionately to the Norwegian partner's share.
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