Shipping and air transport profits are taxable only in the enterprise's State; container rentals and integral interest follow suit. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State. The same rule covers profits from use, maintenance or rental of containers and related equipment used in international traffic, except where such equipment is used solely within the other Contracting State. Interest that is integral to those transport operations is treated as operating profits and Article 11 does not apply. The exclusivity provisions extend to participation in pools, joint businesses or international operating agencies and apply to the Scandinavian Airlines System consortium to the extent of the Norwegian partner's proportional share.
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 are taxable only in the enterprise's State; container rentals and integral interest follow suit.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State. The same rule covers profits from use, maintenance or rental of containers and related equipment used in international traffic, except where such equipment is used solely within the other Contracting State. Interest that is integral to those transport operations is treated as operating profits and Article 11 does not apply. The exclusivity provisions extend to participation in pools, joint businesses or international operating agencies and apply to the Scandinavian Airlines System consortium to the extent of the Norwegian partner's proportional share.
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