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Profits from international shipping and air transport taxable only in the enterprise's State, with specified container and interest exceptions. Profits derived by an enterprise from operating ships or aircraft in international traffic are taxable only in the enterprise's State and include carriage receipts, ticket sales on behalf of others, and incidental rentals; participation in pools or joint businesses is similarly covered. Supplementary activities such as container use, maintenance or rental are taxable only in the enterprise's State unless containers are used solely in the other State, and interest integral to the operation is treated as operational profit and excluded from separate interest rules.
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Provisions expressly mentioned in the judgment/order text.
Profits from international shipping and air transport taxable only in the enterprise's State, with specified container and interest exceptions.
Profits derived by an enterprise from operating ships or aircraft in international traffic are taxable only in the enterprise's State and include carriage receipts, ticket sales on behalf of others, and incidental rentals; participation in pools or joint businesses is similarly covered. Supplementary activities such as container use, maintenance or rental are taxable only in the enterprise's State unless containers are used solely in the other State, and interest integral to the operation is treated as operational profit and excluded from separate interest rules.
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