Taxation of international air transport: profits from aircraft operations are taxable exclusively in the enterprise's contracting state. Income of an enterprise of a Contracting State from the operation of aircraft in international traffic is taxable only in that State; this exclusivity extends to profits from participation in pools, joint businesses or international operating agencies, and operation of aircraft covers carriage of passengers, mail, livestock or goods, ticket sales on behalf of others, incidental leasing and 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.
Taxation of international air transport: profits from aircraft operations are taxable exclusively in the enterprise's contracting state.
Income of an enterprise of a Contracting State from the operation of aircraft in international traffic is taxable only in that State; this exclusivity extends to profits from participation in pools, joint businesses or international operating agencies, and operation of aircraft covers carriage of passengers, mail, livestock or goods, ticket sales on behalf of others, incidental leasing and activities directly connected with such transportation.
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