Shipping profits taxed only in the source state under DTAA; interest tied to ship operations treated as shipping income. Profits from operation of ships in international traffic by an enterprise of a Contracting State are taxable only in that State and include carriage receipts, charter or rental of ships incidental to transportation, rental of containers and related equipment, and gains on alienation of ships, containers and related equipment; interest connected with ship operations is treated as shipping profits and Article 11 does not apply, with these provisions also covering participation in pools, joint businesses or international operating agencies.
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 taxed only in the source state under DTAA; interest tied to ship operations treated as shipping income.
Profits from operation of ships in international traffic by an enterprise of a Contracting State are taxable only in that State and include carriage receipts, charter or rental of ships incidental to transportation, rental of containers and related equipment, and gains on alienation of ships, containers and related equipment; interest connected with ship operations is treated as shipping profits and Article 11 does not apply, with these provisions also covering participation in pools, joint businesses or international operating agencies.
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