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Air transport income exemption bars taxation by the other Contracting State for international aircraft operations and related gains. Income from the operation of aircraft in international traffic by an enterprise of one Contracting State shall not be taxed in the other State; this rule covers participation in pools and treats interest on funds connected with such operations as operational income. 'Operation of aircraft' includes air transportation of persons, livestock, goods or mail, ticket sales on behalf of others, incidental charter leases and other activities directly connected with transportation. Gains from alienation of aircraft whose operational income is taxable only in the enterprise's State shall be taxable only in that State.
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Provisions expressly mentioned in the judgment/order text.
Air transport income exemption bars taxation by the other Contracting State for international aircraft operations and related gains.
Income from the operation of aircraft in international traffic by an enterprise of one Contracting State shall not be taxed in the other State; this rule covers participation in pools and treats interest on funds connected with such operations as operational income. "Operation of aircraft" includes air transportation of persons, livestock, goods or mail, ticket sales on behalf of others, incidental charter leases and other activities directly connected with transportation. Gains from alienation of aircraft whose operational income is taxable only in the enterprise's State shall be taxable only in that State.
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