Taxation of international shipping and air transport permits source-state taxation with limited relief for foreign operators. Profits from operation of ships or aircraft in international traffic are taxable in the enterprise's State, with a contracting State allowed to tax income from foreign enterprises engaged in its territory subject to a statutory tax reduction; container rental income incidental to international operations is taxable only in the enterprise's State of residence unless used solely in the other State; interest integral to shipping or air operations is treated as operational profits and excluded from separate interest provisions; participation in pools, joint businesses or international operating agencies is likewise covered by the source-state rule.
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 permits source-state taxation with limited relief for foreign operators.
Profits from operation of ships or aircraft in international traffic are taxable in the enterprise's State, with a contracting State allowed to tax income from foreign enterprises engaged in its territory subject to a statutory tax reduction; container rental income incidental to international operations is taxable only in the enterprise's State of residence unless used solely in the other State; interest integral to shipping or air operations is treated as operational profits and excluded from separate interest provisions; participation in pools, joint businesses or international operating agencies is likewise covered by the source-state rule.
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