Taxation of international shipping profits limited to the enterprise's State; shipboard management ties residence to home harbour. Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise; if a shipping enterprise's place of effective management is aboard a ship, it is treated as located in the State of the ship's home harbour or, absent a home harbour, the State of the operator's residence. The exclusive taxation rule also covers participation in pools, joint businesses and 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.
Taxation of international shipping profits limited to the enterprise's State; shipboard management ties residence to home harbour.
Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise; if a shipping enterprise's place of effective management is aboard a ship, it is treated as located in the State of the ship's home harbour or, absent a home harbour, the State of the operator's residence. The exclusive taxation rule also covers participation in pools, joint businesses and international operating agencies.
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