Taxation of international shipping and air transport: profits taxable only in the enterprise's State, including pools and joint ventures. Profits of an enterprise from operating ships or aircraft in international traffic are taxable only in that State where the enterprise is resident; this rule also applies to profits from participation in a pool, a joint business or an international operating agency, ensuring a single-State taxing right for such collaborative or agency arrangements.
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 taxable only in the enterprise's State, including pools and joint ventures.
Profits of an enterprise from operating ships or aircraft in international traffic are taxable only in that State where the enterprise is resident; this rule also applies to profits from participation in a pool, a joint business or an international operating agency, ensuring a single-State taxing right for such collaborative or agency arrangements.
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