Taxation of international transport profits limited to the enterprise's state of operation, with reduced tax on shipping activities. Profits from operation of aircraft in international traffic are taxable only in the enterprise's State of operation; profits from operation of ships in international traffic may be taxed in the other State but the tax is reduced by fifty percent. Containers used incidentally in international operations are treated as transport profits, interest integral to operations is treated as such and excluded from Article 11, and participation in pools, joint businesses and international operating agencies is covered by the aircraft rule.
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 transport profits limited to the enterprise's state of operation, with reduced tax on shipping activities.
Profits from operation of aircraft in international traffic are taxable only in the enterprise's State of operation; profits from operation of ships in international traffic may be taxed in the other State but the tax is reduced by fifty percent. Containers used incidentally in international operations are treated as transport profits, interest integral to operations is treated as such and excluded from Article 11, and participation in pools, joint businesses and international operating agencies is covered by the aircraft rule.
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