Taxation of international shipping and air transport profits limited to the enterprise's residence under the tax treaty, including pooled operations. Profits derived by an enterprise from the operation of ships or aircraft in international traffic are taxable only in the Contracting State of which the enterprise is a resident; this rule also applies to profits from participation in a pool, a joint business or an international operating agency.
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 residence under the tax treaty, including pooled operations.
Profits derived by an enterprise from the operation of ships or aircraft in international traffic are taxable only in the Contracting State of which the enterprise is a resident; this rule also applies to profits from participation in a pool, a joint business or an international operating agency.
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