Taxation of international transport profits confined to the state of enterprise; includes incidental container income and related interest. Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; profit includes income from use, maintenance or rental of containers when incidental to such operations. Interest on bank accounts (excluding term deposits) directly connected to those operations is treated as profits from the operation and Article 11 does not apply. The exclusive taxation rule also covers 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 transport profits confined to the state of enterprise; includes incidental container income and related interest.
Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; profit includes income from use, maintenance or rental of containers when incidental to such operations. Interest on bank accounts (excluding term deposits) directly connected to those operations is treated as profits from the operation and Article 11 does not apply. The exclusive taxation rule also covers profits from participation in a pool, a joint business or an international operating agency.
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