Taxation of international shipping and air transport profits limited to the enterprise's residence, including containers and related interest. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; this rule also covers profits from participation in pools, joint businesses, and international operating agencies. Profits from use, maintenance, or rental of containers used in international traffic are taxable only in the resident State unless containers are used solely within the other State. Interest directly connected to ship or aircraft operations is treated as operational profits and excluded from other general income provisions.
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 and air transport profits limited to the enterprise's residence, including containers and related interest.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; this rule also covers profits from participation in pools, joint businesses, and international operating agencies. Profits from use, maintenance, or rental of containers used in international traffic are taxable only in the resident State unless containers are used solely within the other State. Interest directly connected to ship or aircraft operations is treated as operational profits and excluded from other general income provisions.
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