Tax exemption for international shipping and air transport income covers transport receipts, related leasing, interest, and pooled operations. Income from the operation of ships or aircraft in international traffic by an enterprise of one Contracting State is not taxable in the other Contracting State; this exemption covers direct transport receipts and ancillary activities such as ticket sales, directly connected services, leasing/charter arrangements, interest directly connected with operation (excluded from Article 11 withholding), container use/rental incidental to transport, and income 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.
Tax exemption for international shipping and air transport income covers transport receipts, related leasing, interest, and pooled operations.
Income from the operation of ships or aircraft in international traffic by an enterprise of one Contracting State is not taxable in the other Contracting State; this exemption covers direct transport receipts and ancillary activities such as ticket sales, directly connected services, leasing/charter arrangements, interest directly connected with operation (excluded from Article 11 withholding), container use/rental incidental to transport, and income from participation in pools, joint businesses or international operating agencies.
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