Taxation of shipping profits: source-state may tax such income but must provide partial tax relief under the DTAA. Profits of an enterprise of a Contracting State from operating ships in international traffic in the other Contracting State may be taxed in that other State, but the tax chargeable there shall be reduced by an amount equal to fifty per cent of such tax; the same rule applies to profits from participation in a pool, a joint business or an international operating agency.
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 shipping profits: source-state may tax such income but must provide partial tax relief under the DTAA.
Profits of an enterprise of a Contracting State from operating ships in international traffic in the other Contracting State may be taxed in that other State, but the tax chargeable there shall be reduced by an amount equal to fifty per cent of such tax; the same rule applies to profits from participation in a pool, a joint business or an international operating agency.
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