Tax exemption for international air transport profits prevents taxation by the other Contracting State under the DTAA. Profits derived by an enterprise of a Contracting State from the operation of aircraft in international traffic are exempt from tax in the other Contracting State, including profits from participation in a pool, a joint business or an international operating agency, and interest on funds connected with the operation of aircraft in international traffic is regarded as profits from such operations for the purpose of the exemption.
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Provisions expressly mentioned in the judgment/order text.
Tax exemption for international air transport profits prevents taxation by the other Contracting State under the DTAA.
Profits derived by an enterprise of a Contracting State from the operation of aircraft in international traffic are exempt from tax in the other Contracting State, including profits from participation in a pool, a joint business or an international operating agency, and interest on funds connected with the operation of aircraft in international traffic is regarded as profits from such operations for the purpose of the exemption.
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