International traffic profits taxed in the enterprise's state, with special rules for management, containers and related interest. Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's State of residence; aboard-ship effective management is attributed to the State of the home harbor or the operator's residence; container income used in international traffic is taxable only in the resident State unless used solely within the other State; interest integral to such operations is treated as operational profits and Article 11 does not apply; the rule also covers pools, joint businesses and international operating agencies.
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.
International traffic profits taxed in the enterprise's state, with special rules for management, containers and related interest.
Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's State of residence; aboard-ship effective management is attributed to the State of the home harbor or the operator's residence; container income used in international traffic is taxable only in the resident State unless used solely within the other State; interest integral to such operations is treated as operational profits and Article 11 does not apply; the rule also covers pools, joint businesses and international operating agencies.
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