Shipping and air transport profits taxed only in the enterprise's residence; containers, integral interest, and pool participation follow residence rule. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's state of residence; supplementary container use, integral interest on directly connected investments, and profits from participation in pools, joint businesses or international operating agencies are treated as resident-state taxable under the same rule, except where containers are used solely within the other Contracting State.
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 taxed only in the enterprise's residence; containers, integral interest, and pool participation follow residence rule.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's state of residence; supplementary container use, integral interest on directly connected investments, and profits from participation in pools, joint businesses or international operating agencies are treated as resident-state taxable under the same rule, except where containers are used solely within the other Contracting State.
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