Shipping profits taxation: place of effective management governs primary taxability, with limited source taxation allowed under conditions. Profits from the operation of ships in international traffic are taxable in the State of the enterprise's place of effective management, though the other State may tax profits attributable to more-than-casual operations within its territory under temporal and quantitative limits and at a reduced effective rate. If management is aboard a ship, the place of effective management is deemed to be the State of the home harbour or, if none, the State of the operator's residence. Interest connected to ship operation is treated as shipping profits and Article 11 does not apply. Shipping profits include container-related income and full or bareboat ship rentals when incidental, and the Article covers pool and joint business participation.
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Provisions expressly mentioned in the judgment/order text.
Shipping profits taxation: place of effective management governs primary taxability, with limited source taxation allowed under conditions.
Profits from the operation of ships in international traffic are taxable in the State of the enterprise's place of effective management, though the other State may tax profits attributable to more-than-casual operations within its territory under temporal and quantitative limits and at a reduced effective rate. If management is aboard a ship, the place of effective management is deemed to be the State of the home harbour or, if none, the State of the operator's residence. Interest connected to ship operation is treated as shipping profits and Article 11 does not apply. Shipping profits include container-related income and full or bareboat ship rentals when incidental, and the Article covers pool and joint business participation.
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