International traffic taxation: operational profits of ships and aircraft taxed at place of effective management, with related interest treated as operational income. Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State where the enterprise's place of effective management is situated; if that place is aboard a ship, it is deemed to be in the State of the ship's registration or, if none, the State of the operator's residence. Income from containers used in international transport is taxable only in the enterprise's State. Interest directly connected and incidental to such operations is treated as operational profits, and the place-of-management 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.
International traffic taxation: operational profits of ships and aircraft taxed at place of effective management, with related interest treated as operational income.
Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State where the enterprise's place of effective management is situated; if that place is aboard a ship, it is deemed to be in the State of the ship's registration or, if none, the State of the operator's residence. Income from containers used in international transport is taxable only in the enterprise's State. Interest directly connected and incidental to such operations is treated as operational profits, and the place-of-management rule also applies to pools, joint businesses and international operating agencies.
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