International traffic profits taxable only in the enterprise's Contracting State; includes related interest, container and rental income. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State, including profits from pools, joint businesses or international operating agencies; interest linked to such operations is treated as operational profits and Article 11 does not apply. 'Profits from the operation' include carriage of passengers, mail, livestock and goods by owners, lessees or charterers and expressly cover ticket sales for others, container use/maintenance/rental, incidental ship or aircraft rentals, and other activities directly connected with international operation.
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.
International traffic profits taxable only in the enterprise's Contracting State; includes related interest, container and rental income.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State, including profits from pools, joint businesses or international operating agencies; interest linked to such operations is treated as operational profits and Article 11 does not apply. "Profits from the operation" include carriage of passengers, mail, livestock and goods by owners, lessees or charterers and expressly cover ticket sales for others, container use/maintenance/rental, incidental ship or aircraft rentals, and other activities directly connected with international operation.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
