Air transport income exemption prevents taxation by the other Contracting State unless flights occur mainly within that State. Income from the operation of aircraft by an enterprise of one Contracting State is not taxable in the other Contracting State unless the aircraft is operated wholly or mainly within that other State; this rule also covers participations in pools and treats interest on funds directly connected with international aircraft operation as income from that operation.
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.
Air transport income exemption prevents taxation by the other Contracting State unless flights occur mainly within that State.
Income from the operation of aircraft by an enterprise of one Contracting State is not taxable in the other Contracting State unless the aircraft is operated wholly or mainly within that other State; this rule also covers participations in pools and treats interest on funds directly connected with international aircraft operation as income from that operation.
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