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of <h1>International Shipping Profits Taxed Where Management Resides; 50% Tax Reduction for Foreign Operations.</h1> Profits from international shipping or air transport operations by an enterprise of a Contracting State are taxable only in the state where the enterprise's effective management is located. If management is aboard a ship, it is considered in the state of the ship's home harbor or the operator's residence. 'Operation' includes transportation of passengers, mail, livestock, or goods, and related activities. Profits from ships operating in another state may be taxed there but with a 50% reduction. Profits from container use in international traffic are taxed in the enterprise's resident state unless used solely in the other state. Interest linked to these operations is considered part of the profits, and joint ventures are included.
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