Taxation of international shipping and air transport: profits from operation and related rentals taxable only in enterprise's state. Profits from operation of ships or aircraft in international traffic, including full time, voyage or bareboat rentals, are taxable only in the enterprise's State. Income from use, maintenance or rental of containers and related equipment is similarly taxable only in that State, except where such containers are used solely for transport within the other Contracting State. Interest directly connected with the operation of ships or aircraft is treated as operational profits and the separate interest provision does not apply.
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 international shipping and air transport: profits from operation and related rentals taxable only in enterprise's state.
Profits from operation of ships or aircraft in international traffic, including full time, voyage or bareboat rentals, are taxable only in the enterprise's State. Income from use, maintenance or rental of containers and related equipment is similarly taxable only in that State, except where such containers are used solely for transport within the other Contracting State. Interest directly connected with the operation of ships or aircraft is treated as operational profits and the separate interest provision does not apply.
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