Shipping and air transport profits taxable only in the enterprise's state, including bare boat charters and related rentals. Profits from operating ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State; this includes income from bare boat charters, incidental use/maintenance/rental of containers and related equipment, interest on investments integral to the operation, and profits from participation in pools, joint businesses or 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 state, including bare boat charters and related rentals.
Profits from operating ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State; this includes income from bare boat charters, incidental use/maintenance/rental of containers and related equipment, interest on investments integral to the operation, and profits from participation in pools, joint businesses or international operating agencies.
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