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Taxation of international air transport profits limited to state of effective management; rentals and related interest counted as such profits. Profits from operating aircraft in international traffic are taxable only in the State of the enterprise's place of effective management; this includes incidental bareboat rental profits and interest connected with aircraft operations (with Article 11 not applying to such interest), and extends to 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 air transport profits limited to state of effective management; rentals and related interest counted as such profits.
Profits from operating aircraft in international traffic are taxable only in the State of the enterprise's place of effective management; this includes incidental bareboat rental profits and interest connected with aircraft operations (with Article 11 not applying to such interest), and extends to participation in pools, joint businesses or international operating agencies.
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