Taxation of international shipping and air transport profits confined to the enterprise's State of residence; containers and interest treated accordingly. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence. Profits from use, maintenance or rental of containers used for international transport are taxable only in the resident State unless containers are used solely within the other State. Interest integral to such operations is treated as operational profits and not subject to separate interest provisions. Residence-based exclusivity 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.
Taxation of international shipping and air transport profits confined to the enterprise's State of residence; containers and interest treated accordingly.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence. Profits from use, maintenance or rental of containers used for international transport are taxable only in the resident State unless containers are used solely within the other State. Interest integral to such operations is treated as operational profits and not subject to separate interest provisions. Residence-based exclusivity also covers participation in pools, joint businesses and international operating agencies.
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