Taxation of shipping and air transport: profits taxed at enterprise's place of effective management, with limited source-state taxation. Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State where the enterprise's place of effective management is situated, with shipboard management deemed located at the home harbor or the operator's State of residence; source-State taxation of shipping profits is nevertheless permitted subject to a statutory reduction; container rental income is taxable only in the resident State unless used solely in the other State; interest integral to operations is treated as operational profits and Article 11 does not apply; and the rule extends to pools, joint businesses and 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: profits taxed at enterprise's place of effective management, with limited source-state taxation.
Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State where the enterprise's place of effective management is situated, with shipboard management deemed located at the home harbor or the operator's State of residence; source-State taxation of shipping profits is nevertheless permitted subject to a statutory reduction; container rental income is taxable only in the resident State unless used solely in the other State; interest integral to operations is treated as operational profits and Article 11 does not apply; and the rule extends to pools, joint businesses and international operating agencies.
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