Profits from operation of ships and aircraft taxable only in the enterprise's resident State under the treaty. Profits from the operation of ships or aircraft in international traffic are taxable only in the enterprise's State of residence; income from use, maintenance or rental of containers used in international traffic is likewise taxable only in the resident State unless used solely within the other Contracting State. Interest connected with such operations is treated as operating profits and excluded from the Article on interest, and paragraph 1's exclusive residence-state rule also covers participation in 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.
Profits from operation of ships and aircraft taxable only in the enterprise's resident State under the treaty.
Profits from the operation of ships or aircraft in international traffic are taxable only in the enterprise's State of residence; income from use, maintenance or rental of containers used in international traffic is likewise taxable only in the resident State unless used solely within the other Contracting State. Interest connected with such operations is treated as operating profits and excluded from the Article on interest, and paragraph 1's exclusive residence-state rule also covers participation in pools, joint businesses and international operating agencies.
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