Taxation of international transport profits: profits from ships or aircraft taxable only in the enterprise's resident State. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; inland transport forming part of international operations is treated similarly. Income from use, maintenance or rental of containers incidental to international operations is taxable only in the resident State unless containers are used solely within the other Contracting State. Interest integral and incidental to the operation of ships or aircraft is treated as profits from those operations and not subject to separate interest provisions. Profits from pools, joint businesses or international operating agencies are covered by the same 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: profits from ships or aircraft taxable only in the enterprise's resident State.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; inland transport forming part of international operations is treated similarly. Income from use, maintenance or rental of containers incidental to international operations is taxable only in the resident State unless containers are used solely within the other Contracting State. Interest integral and incidental to the operation of ships or aircraft is treated as profits from those operations and not subject to separate interest provisions. Profits from pools, joint businesses or international operating agencies are covered by the same rule.
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