Taxation of international transport: operation profits taxable only in the enterprise's state; containers and integral investment income treated similarly. Profits from the operation of ships or aircraft in international traffic are taxable only in the enterprise's State; container use, maintenance or rental income used in international traffic is likewise taxable only in the resident State unless containers are used solely in the other State. Interest on investments integral to such operations is treated as operation profits and is excluded from separate interest provisions. The exclusive taxing rule also covers participation in pools, joint businesses and international operating agencies engaged in international traffic.
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: operation profits taxable only in the enterprise's state; containers and integral investment income treated similarly.
Profits from the operation of ships or aircraft in international traffic are taxable only in the enterprise's State; container use, maintenance or rental income used in international traffic is likewise taxable only in the resident State unless containers are used solely in the other State. Interest on investments integral to such operations is treated as operation profits and is excluded from separate interest provisions. The exclusive taxing rule also covers participation in pools, joint businesses and international operating agencies engaged in international traffic.
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