Taxation of shipping income: residence-based taxation with limited source-state taxation for certain international voyages. Income from operation of ships in international traffic by an enterprise of a Contracting State is generally taxable only in that State, but the other Contracting State may tax income from voyages between its ports and third-country ports subject to a ceiling that limits tax to either fifty per cent of its otherwise applicable tax or two and a half per cent of the gross amount payable. The gross amount payable includes receipts for carriage from specified ports, interest connected with ship operation arising in the other State, and amounts for use, maintenance or rent of containers; interest so arising is treated as shipping income and Article 12 does not apply.
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 shipping income: residence-based taxation with limited source-state taxation for certain international voyages.
Income from operation of ships in international traffic by an enterprise of a Contracting State is generally taxable only in that State, but the other Contracting State may tax income from voyages between its ports and third-country ports subject to a ceiling that limits tax to either fifty per cent of its otherwise applicable tax or two and a half per cent of the gross amount payable. The gross amount payable includes receipts for carriage from specified ports, interest connected with ship operation arising in the other State, and amounts for use, maintenance or rent of containers; interest so arising is treated as shipping income and Article 12 does not apply.
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