Taxation of international shipping and air transport confined to the enterprise's residence; containers and integral interest treated as transport profits. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; aboard-ship effective management is deemed located in the State of the ship's home harbor or the operator's residence if no home harbor exists. Use, maintenance or rental of containers incidental to international transport and interest integral to such operations are treated as transport profits, with the interest excluded from the scope of Article 11, and participation in pools or joint businesses similarly covered.
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 confined to the enterprise's residence; containers and integral interest treated as transport profits.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; aboard-ship effective management is deemed located in the State of the ship's home harbor or the operator's residence if no home harbor exists. Use, maintenance or rental of containers incidental to international transport and interest integral to such operations are treated as transport profits, with the interest excluded from the scope of Article 11, and participation in pools or joint businesses similarly covered.
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