Taxation of international air transport profits: operational income and disposal gains are taxable only in the enterprise's state. Profits from the operation of aircraft in international traffic by an enterprise of one Contracting State shall be taxable only in that State and not in the other Contracting State; this rule covers participation in pools and activities directly connected with such transportation, including sale of tickets, incidental charter leasing and carriage of persons, livestock, goods or mail. Gains from the alienation of aircraft used by the enterprise whose operational income is taxable only in that State shall also be 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 air transport profits: operational income and disposal gains are taxable only in the enterprise's state.
Profits from the operation of aircraft in international traffic by an enterprise of one Contracting State shall be taxable only in that State and not in the other Contracting State; this rule covers participation in pools and activities directly connected with such transportation, including sale of tickets, incidental charter leasing and carriage of persons, livestock, goods or mail. Gains from the alienation of aircraft used by the enterprise whose operational income is taxable only in that State shall also be taxable only in that State.
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