Shipping and air transport taxation: profits from international operations taxable only in enterprise's resident state; related interest treated as operational. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; if effective management is aboard a ship, it is deemed located in the State of the home harbour or the operator's resident State. Container income used in international transport is taxable only in the resident State unless used solely within the other State. Interest integral to operations is treated as operational profits and Article 11 does not apply; the resident-State 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 taxation: profits from international operations taxable only in enterprise's resident state; related interest treated as operational.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; if effective management is aboard a ship, it is deemed located in the State of the home harbour or the operator's resident State. Container income used in international transport is taxable only in the resident State unless used solely within the other State. Interest integral to operations is treated as operational profits and Article 11 does not apply; the resident-State rule also covers pools, joint businesses and international operating agencies.
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