Taxation of shipping and air transport limited to the enterprise's residence, including related containers and integral investment interest. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence. This includes profits from use, maintenance or rental of containers incidental to such operations unless containers are used solely within the other State. Interest on investments integral to the operation is treated as operation-derived profits and excluded from other interest provisions. The same allocation applies to profits from participation in pools, joint businesses or 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 shipping and air transport limited to the enterprise's residence, including related containers and integral investment interest.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence. This includes profits from use, maintenance or rental of containers incidental to such operations unless containers are used solely within the other State. Interest on investments integral to the operation is treated as operation-derived profits and excluded from other interest provisions. The same allocation applies to profits from participation in pools, joint businesses or international operating agencies.
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