Taxation of international shipping and air transport profits limited to resident State; interest and pooling treated as transport income. Profits from operating ships or aircraft in international traffic by a resident enterprise are taxable only in the resident State; such profits include carriage revenues, ticket sales, rental of vessels or aircraft connected with transport, and income from use or rental of containers. Interest directly connected with these operations is regarded as transport profits and not governed by the separate interest provision. The exclusive taxing right also covers 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.
Taxation of international shipping and air transport profits limited to resident State; interest and pooling treated as transport income.
Profits from operating ships or aircraft in international traffic by a resident enterprise are taxable only in the resident State; such profits include carriage revenues, ticket sales, rental of vessels or aircraft connected with transport, and income from use or rental of containers. Interest directly connected with these operations is regarded as transport profits and not governed by the separate interest provision. The exclusive taxing right also covers profits from participation in pools, joint businesses, or international operating agencies.
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