Taxation of international shipping and air transport profits taxable only in state of effective management; includes container and interest rules. Profits from operation of ships or aircraft in international traffic are taxable only in the Contracting State where the enterprise's place of effective management is located; if that place is aboard a ship it is deemed to be in the State of the ship operator's residence. The same rule applies to participation in pools or joint operating agencies. Use, maintenance or rental of containers incidental to international transport is taxable only in the State of effective management unless containers are used solely within the other State. Interest integral to such operations is treated as operational profits and not subject to general interest provisions.
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 profits taxable only in state of effective management; includes container and interest rules.
Profits from operation of ships or aircraft in international traffic are taxable only in the Contracting State where the enterprise's place of effective management is located; if that place is aboard a ship it is deemed to be in the State of the ship operator's residence. The same rule applies to participation in pools or joint operating agencies. Use, maintenance or rental of containers incidental to international transport is taxable only in the State of effective management unless containers are used solely within the other State. Interest integral to such operations is treated as operational profits and not subject to general interest provisions.
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