Shipping and air transport profits taxable only in the enterprise's state, covering pools, leases, containers and related interest. Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise and include income from participation in pools, joint businesses and international operating agencies; interest linked to such operations is treated as operational profits. 'Profits from the operation of ships or aircraft in international traffic' cover transport of passengers, mail, livestock or goods by owners, lessees or charterers, sale of tickets for others, incidental leases, container use or rental, and other activities directly connected with such transportation.
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 state, covering pools, leases, containers and related interest.
Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise and include income from participation in pools, joint businesses and international operating agencies; interest linked to such operations is treated as operational profits. "Profits from the operation of ships or aircraft in international traffic" cover transport of passengers, mail, livestock or goods by owners, lessees or charterers, sale of tickets for others, incidental leases, container use or rental, and other activities directly connected with such transportation.
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