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        DTAA

        Article 8 - Shipping and Air Transport

        Armenia

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        Taxation of international shipping profits: residence State has exclusive taxing right for operations and related pooling activities. Profits from operating ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State, including profits from participation in a pool, joint business or international operating agency; similarly, income from use, maintenance or rental of containers used for international traffic is taxable only in the resident State unless the containers are used solely within the other Contracting State.
                          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 profits: residence State has exclusive taxing right for operations and related pooling activities.

                                Profits from operating ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State, including profits from participation in a pool, joint business or international operating agency; similarly, income from use, maintenance or rental of containers used for international traffic is taxable only in the resident State unless the containers are used solely within the other Contracting State.


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