Definition of enterprise as a designated airline determines tax treatment of international air traffic under the DTAA. The treaty defines key terms: Contracting State and tax refer to the two Parties; enterprise of a Contracting State means an airline designated by each State; international air traffic is carriage by such an enterprise except when operated solely within the other State; operation of aircraft covers carriage of persons, livestock, goods or mail, ticket sales on behalf of others, incidental leases and activities directly connected with transportation. Undefined terms are to be given the meaning they carry under the domestic tax law of the State applying the provision.
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Provisions expressly mentioned in the judgment/order text.
Definition of enterprise as a designated airline determines tax treatment of international air traffic under the DTAA.
The treaty defines key terms: Contracting State and tax refer to the two Parties; enterprise of a Contracting State means an airline designated by each State; international air traffic is carriage by such an enterprise except when operated solely within the other State; operation of aircraft covers carriage of persons, livestock, goods or mail, ticket sales on behalf of others, incidental leases and activities directly connected with transportation. Undefined terms are to be given the meaning they carry under the domestic tax law of the State applying the provision.
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