Shipping and air transport profits: taxable only in the enterprise's residence state when derived from international operations. Profits from operation of ships and aircraft in international traffic are taxable only in the enterprise's Contracting State of residence; similarly, income from use, maintenance or rental of containers used in international traffic is taxable only in the resident State except where containers are used solely within the other State. Interest on investments directly connected and integral to such operations is treated as operational profits and excluded from separate interest provisions. The rule also applies to 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 residence state when derived from international operations.
Profits from operation of ships and aircraft in international traffic are taxable only in the enterprise's Contracting State of residence; similarly, income from use, maintenance or rental of containers used in international traffic is taxable only in the resident State except where containers are used solely within the other State. Interest on investments directly connected and integral to such operations is treated as operational profits and excluded from separate interest provisions. The rule also applies to profits from participation in pools, joint businesses or international operating agencies.
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