Shipping and air transport profits taxable only in the enterprise's State for international operations, including containers and related investments. Profits from operating ships and aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State; this covers profits from use, maintenance or rental of containers and related equipment. Interest on investments made as an integral part of that business is treated as profits from such operations and is subject to the same exclusive taxing rule. The rule additionally applies to profits from participation in pools, joint businesses or international operating agencies connected with international transport.
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 for international operations, including containers and related investments.
Profits from operating ships and aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State; this covers profits from use, maintenance or rental of containers and related equipment. Interest on investments made as an integral part of that business is treated as profits from such operations and is subject to the same exclusive taxing rule. The rule additionally applies to profits from participation in pools, joint businesses or international operating agencies connected with international transport.
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