Taxation of international shipping and air transport: profits taxable only in the enterprise's state, with specified operational exceptions. Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise, including profits from full time or bareboat rentals and interest directly connected with such operations; the rule also covers container use, maintenance or rental except when containers are used solely between places within the other Contracting State, and applies to 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 and air transport: profits taxable only in the enterprise's state, with specified operational exceptions.
Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise, including profits from full time or bareboat rentals and interest directly connected with such operations; the rule also covers container use, maintenance or rental except when containers are used solely between places within the other Contracting State, and applies to pools, joint businesses and international operating agencies.
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