Taxation of shipping and air transport profits limited to source state, with exception for domestic voyages and related income. Profits from the operation of ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State, including revenue from carriage of passengers, mail, livestock or goods, ticket sales on behalf of others, activities directly connected with transport, incidental rentals, container use and related equipment, and participation in pools or joint operating arrangements; interest connected with such operations is treated as such profits and excluded from Article 11, while voyages principally transporting between places in the other State may be taxed by that State and the Article excludes drilling rigs and vessels whose main function is non-transport activities.
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Provisions expressly mentioned in the judgment/order text.
Taxation of shipping and air transport profits limited to source state, with exception for domestic voyages and related income.
Profits from the operation of ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State, including revenue from carriage of passengers, mail, livestock or goods, ticket sales on behalf of others, activities directly connected with transport, incidental rentals, container use and related equipment, and participation in pools or joint operating arrangements; interest connected with such operations is treated as such profits and excluded from Article 11, while voyages principally transporting between places in the other State may be taxed by that State and the Article excludes drilling rigs and vessels whose main function is non-transport activities.
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