Taxation of international shipping and air transport: exclusive taxing right for profits and related operational income. Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's Contracting State, including profits from use, maintenance or rental of containers and related equipment; interest on investments made as an integral part of such operations is treated as operating profits and excluded from the separate interest provision, and the exclusive taxing rule also applies to 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.
Taxation of international shipping and air transport: exclusive taxing right for profits and related operational income.
Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's Contracting State, including profits from use, maintenance or rental of containers and related equipment; interest on investments made as an integral part of such operations is treated as operating profits and excluded from the separate interest provision, and the exclusive taxing rule also applies to pools, joint businesses and international operating agencies.
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