Air transport income exemption prevents taxation by other state unless aircraft operates mainly within that state. Income from the operation of aircraft by an enterprise of one Contracting State is not taxable in the other Contracting State unless the aircraft is operated wholly or mainly between places within that other State. The rule also applies to participations in pools by air transport enterprises, and interest on funds directly connected with the operation of aircraft in international traffic is regarded as income from that operation.
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.
Air transport income exemption prevents taxation by other state unless aircraft operates mainly within that state.
Income from the operation of aircraft by an enterprise of one Contracting State is not taxable in the other Contracting State unless the aircraft is operated wholly or mainly between places within that other State. The rule also applies to participations in pools by air transport enterprises, and interest on funds directly connected with the operation of aircraft in international traffic is regarded as income from that operation.
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