Shipping and air transport profits taxable only in the enterprise's Contracting State, with specific management and container rules. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; a shipboard place of effective management is deemed located in the State of the ship's home harbour or the operator's residence if no home harbour exists. Profits from use, maintenance or rental of containers used in international traffic are taxable only in the resident State unless containers are used solely within the other State. Paragraph 1's exclusive taxing rule also covers pools, joint businesses and international operating agencies.
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.
Shipping and air transport profits taxable only in the enterprise's Contracting State, with specific management and container rules.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; a shipboard place of effective management is deemed located in the State of the ship's home harbour or the operator's residence if no home harbour exists. Profits from use, maintenance or rental of containers used in international traffic are taxable only in the resident State unless containers are used solely within the other State. Paragraph 1's exclusive taxing rule also covers pools, joint businesses and international operating agencies.
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