Taxation of international shipping: income from operation of ships is taxable only in the enterprise's State, with specified exceptions. Income from the operation of ships in international traffic by an enterprise of a Contracting State is taxable only in that State, except for income from journeys between places within a single Contracting State. Bareboat rental incidental to ship operation is included. The rule also applies to container use, maintenance or rental and to participation in pools, joint businesses or international operating agencies. Gains on alienation of ships or containers are taxable only in that State where operation income was so taxed or the ships or containers were outside the other Contracting State at alienation.
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: income from operation of ships is taxable only in the enterprise's State, with specified exceptions.
Income from the operation of ships in international traffic by an enterprise of a Contracting State is taxable only in that State, except for income from journeys between places within a single Contracting State. Bareboat rental incidental to ship operation is included. The rule also applies to container use, maintenance or rental and to participation in pools, joint businesses or international operating agencies. Gains on alienation of ships or containers are taxable only in that State where operation income was so taxed or the ships or containers were outside the other Contracting State at alienation.
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