Taxation of international shipping and air transport profits limited to state of enterprise's effective management. Profits of an enterprise registered and effectively managed in a Contracting State from operating ships or aircraft in international traffic are taxable only in that State; this includes transport of passengers, mail, livestock and goods, ticket sales, activities directly connected with transportation, and rental incidental to such transportation. Use, maintenance or rental of containers connected with international traffic, participation in pools or joint operations, interest on funds connected with such operations treated as profits, and gains on alienation of ships, aircraft or containers are likewise taxable only in that State.
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 profits limited to state of enterprise's effective management.
Profits of an enterprise registered and effectively managed in a Contracting State from operating ships or aircraft in international traffic are taxable only in that State; this includes transport of passengers, mail, livestock and goods, ticket sales, activities directly connected with transportation, and rental incidental to such transportation. Use, maintenance or rental of containers connected with international traffic, participation in pools or joint operations, interest on funds connected with such operations treated as profits, and gains on alienation of ships, aircraft or containers are likewise taxable only in that State.
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