Avoidance of double taxation: agreement on enterprises operating aircraft given domestic legal effect, defining enterprise, international traffic. Notification gives domestic legal effect to an agreement for the avoidance of double taxation concerning income of enterprises operating aircraft. The Agreement defines key terms: enterprise of a Contracting State (designated or authorised airlines), 'international traffic' (transport by such enterprises except when solely between places in the other Contracting State), and 'operation of aircraft' (transport and directly connected activities). Undefined terms are to be given the meaning they have under the domestic tax laws of the applying 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.
Avoidance of double taxation: agreement on enterprises operating aircraft given domestic legal effect, defining enterprise, international traffic.
Notification gives domestic legal effect to an agreement for the avoidance of double taxation concerning income of enterprises operating aircraft. The Agreement defines key terms: enterprise of a Contracting State (designated or authorised airlines), "international traffic" (transport by such enterprises except when solely between places in the other Contracting State), and "operation of aircraft" (transport and directly connected activities). Undefined terms are to be given the meaning they have under the domestic tax laws of the applying Contracting State.
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