Taxation of shipping and air transport profits limited to the enterprise's state, with narrow exception for domestic voyages. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State, except that profits from a voyage principally transporting passengers or goods between places in the other Contracting State may be taxed in that other State. Qualifying profits include carriage of passengers, mail, livestock or goods, ticket sales on behalf of others, activities directly connected with transportation, incidental rental of ships or aircraft, container use and rental, participation in pools or joint operations, and interest connected with such operations; drilling rigs and non transport vessels are excluded.
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 and air transport profits limited to the enterprise's state, with narrow exception for domestic voyages.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State, except that profits from a voyage principally transporting passengers or goods between places in the other Contracting State may be taxed in that other State. Qualifying profits include carriage of passengers, mail, livestock or goods, ticket sales on behalf of others, activities directly connected with transportation, incidental rental of ships or aircraft, container use and rental, participation in pools or joint operations, and interest connected with such operations; drilling rigs and non transport vessels are excluded.
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