Taxation of shipping and air transport profits limited to residence state; other State may tax third-country voyages with reduction. Profits from operation or rental of ships or aircraft in international traffic and rental of containers incidental to that operation are taxable only in the enterprise's Contracting State; this includes participation in pools, joint businesses or international operating agencies. Interest directly connected to such operations is treated as operational profits and Article 11 does not apply if incidental. Profits from voyages between the ports of the other Contracting State and third countries may be taxed by that other State but such tax must be reduced by two-thirds.
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 shipping and air transport profits limited to residence state; other State may tax third-country voyages with reduction.
Profits from operation or rental of ships or aircraft in international traffic and rental of containers incidental to that operation are taxable only in the enterprise's Contracting State; this includes participation in pools, joint businesses or international operating agencies. Interest directly connected to such operations is treated as operational profits and Article 11 does not apply if incidental. Profits from voyages between the ports of the other Contracting State and third countries may be taxed by that other State but such tax must be reduced by two-thirds.
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