Taxation of international shipping and air transport profits follows the enterprise's place of effective management, with specific rules for containers and integral interest. Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise's place of effective management; if that place is aboard a ship it is deemed to be in the State of the ship's home harbor or the operator's residence. Income from use, maintenance, or rental of containers used in international traffic is taxable only in the resident State unless used solely in the other State. Interest integral to transport operations is treated as operational profits, and the exclusive taxing rule covers participation in pools, joint businesses, and international operating agencies.
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Provisions expressly mentioned in the judgment/order text.
Taxation of international shipping and air transport profits follows the enterprise's place of effective management, with specific rules for containers and integral interest.
Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise's place of effective management; if that place is aboard a ship it is deemed to be in the State of the ship's home harbor or the operator's residence. Income from use, maintenance, or rental of containers used in international traffic is taxable only in the resident State unless used solely in the other State. Interest integral to transport operations is treated as operational profits, and the exclusive taxing rule covers participation in pools, joint businesses, and international operating agencies.
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