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 ... Summary
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.
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