Taxation of international shipping and air transport: exclusive taxing rights allocated to the enterprise's Contracting State for transport profits. Profits from operation of ships and aircraft in international traffic are taxable only in the Contracting State of the enterprise; this includes transport of passengers, livestock and goods, income from use, maintenance or rental of containers, and interest incidental to the operation, which is treated as transport profit rather than separate interest; the place of effective management aboard a ship is deemed in the State of the ship's home harbor or, absent a home harbor, in the State of residence of the operator; participation in pools, joint businesses or international operating agencies is covered by the same exclusive taxing rule.
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 shipping and air transport: exclusive taxing rights allocated to the enterprise's Contracting State for transport profits.
Profits from operation of ships and aircraft in international traffic are taxable only in the Contracting State of the enterprise; this includes transport of passengers, livestock and goods, income from use, maintenance or rental of containers, and interest incidental to the operation, which is treated as transport profit rather than separate interest; the place of effective management aboard a ship is deemed in the State of the ship's home harbor or, absent a home harbor, in the State of residence of the operator; participation in pools, joint businesses or international operating agencies is covered by the same exclusive taxing rule.
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