Shipping and air transport profits taxable only in the enterprise's residence state, with special rules for containers and connected interest. Profits from operating ships or aircraft in international traffic by a resident enterprise are taxable only in that State; the same applies to profits from use, maintenance or rental of containers for international transport unless containers are used solely within the other State. Interest on investments integral and directly connected to such operations is treated as operational profits and not subject to separate interest provisions. The exclusive taxing right also covers participation in 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.
Shipping and air transport profits taxable only in the enterprise's residence state, with special rules for containers and connected interest.
Profits from operating ships or aircraft in international traffic by a resident enterprise are taxable only in that State; the same applies to profits from use, maintenance or rental of containers for international transport unless containers are used solely within the other State. Interest on investments integral and directly connected to such operations is treated as operational profits and not subject to separate interest provisions. The exclusive taxing right also covers participation in pools, joint businesses and international operating agencies.
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