Shipping and Air Transport profits taxable only in the enterprise's state of residence, including container and related interest rules. Profits from operating ships or aircraft in international traffic by an enterprise are taxable only in the State of the enterprise's residence; this rule includes profits from use, maintenance or rental of containers used in international transport unless used solely within the other Contracting State, treats interest on funds connected with such operations as operational profits excluded from the interest Article, and extends to profits from participation in pools, joint businesses or international operating agencies.
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.
Shipping and Air Transport profits taxable only in the enterprise's state of residence, including container and related interest rules.
Profits from operating ships or aircraft in international traffic by an enterprise are taxable only in the State of the enterprise's residence; this rule includes profits from use, maintenance or rental of containers used in international transport unless used solely within the other Contracting State, treats interest on funds connected with such operations as operational profits excluded from the interest Article, and extends to profits from participation in pools, joint businesses or international operating agencies.
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