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 ... Summary
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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