Taxation of international transport profits: residence-state primary taxing right; source-state limited transitional taxation permitted under specified ceilings. Profits from the operation of aircraft and ships in international traffic by an enterprise of a Contracting State are taxable only in that State, subject for ship profits to a limited transitional exception allowing the other State to tax those profits during an initial period at progressively reduced ceilings; the rules also extend to participation in pools, joint businesses or international operating agencies and apply to the Japanese enterprise tax and any similar tax in India.
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: residence-state primary taxing right; source-state limited transitional taxation permitted under specified ceilings.
Profits from the operation of aircraft and ships in international traffic by an enterprise of a Contracting State are taxable only in that State, subject for ship profits to a limited transitional exception allowing the other State to tax those profits during an initial period at progressively reduced ceilings; the rules also extend to participation in pools, joint businesses or international operating agencies and apply to the Japanese enterprise tax and any similar tax in India.
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