Shipping profits in international traffic are taxable only in the enterprise's Contracting State, covering pools and container rentals. Profits from the operation of ships in international traffic are taxable only in the Contracting State of the enterprise; this exclusivity also covers profits from participation in pools, joint businesses or international operating agencies engaged in ship operations, and includes profits from the use, maintenance or rental of containers (including trailers and related equipment) when connected with transport of goods in international traffic.
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 profits in international traffic are taxable only in the enterprise's Contracting State, covering pools and container rentals.
Profits from the operation of ships in international traffic are taxable only in the Contracting State of the enterprise; this exclusivity also covers profits from participation in pools, joint businesses or international operating agencies engaged in ship operations, and includes profits from the use, maintenance or rental of containers (including trailers and related equipment) when connected with transport of goods in international traffic.
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