International traffic taxation: income from ships or aircraft operations taxable only in the enterprise's Contracting State. Income from operation of ships or aircraft in international traffic is taxable exclusively in the Contracting State of which the enterprise is a resident. Income from use, maintenance or rental of containers used for international transport is likewise taxable only in that State unless containers are used solely within the other State. A shipping enterprise whose effective management is aboard a ship is deemed managed in the State of the ship's home harbour or, lacking that, the operator's State of residence. Interest connected with such operations is treated as income from international traffic, and profits from pools or joint operations fall under the same rule.
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.
International traffic taxation: income from ships or aircraft operations taxable only in the enterprise's Contracting State.
Income from operation of ships or aircraft in international traffic is taxable exclusively in the Contracting State of which the enterprise is a resident. Income from use, maintenance or rental of containers used for international transport is likewise taxable only in that State unless containers are used solely within the other State. A shipping enterprise whose effective management is aboard a ship is deemed managed in the State of the ship's home harbour or, lacking that, the operator's State of residence. Interest connected with such operations is treated as income from international traffic, and profits from pools or joint operations fall under the same rule.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
