Taxation of international shipping and air transport profits limited to the enterprise's state; related containers and interest likewise. Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise; the same rule applies to profits from the use, maintenance or rental of containers used in international traffic. If effective management of a shipping enterprise is aboard a ship, it is deemed situated in the State of the ship's home harbour or, if none, the State of the operator's residence. Interest directly connected with such operations is regarded as operating profits when integral to the business, and participation in pools or joint businesses is similarly covered.
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 limited to the enterprise's state; related containers and interest likewise.
Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise; the same rule applies to profits from the use, maintenance or rental of containers used in international traffic. If effective management of a shipping enterprise is aboard a ship, it is deemed situated in the State of the ship's home harbour or, if none, the State of the operator's residence. Interest directly connected with such operations is regarded as operating profits when integral to the business, and participation in pools or joint businesses is similarly covered.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
