Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
Try it now in Case Laws →
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of <h1>International Traffic Profits Taxed Where Enterprise Management Resides; Includes Joint Ventures; Excludes Article 11 Interest Rules.</h1> Profits from operating ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in the state where the enterprise's effective management is located. If the management is on a ship, it is considered located in the state where the ship's operator resides. Profits from using containers in international traffic are taxable only in the state of effective management unless used solely in the other state. Interest related to such operations is treated as operational profit, excluding Article 11 provisions. These rules also apply to profits from participation in joint ventures or international agencies.
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