International traffic profits taxed only in the enterprise's resident state, including container rentals and incidental interest treatment. Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's State of residence; this includes transport receipts for passengers, goods, mail and livestock, participation in pools, joint businesses and international operating agencies. Income from use or rental of containers and related transport equipment used by the enterprise in international traffic is taxable only in the resident State unless such equipment is used solely within the other Contracting State. Interest directly connected with operation, if incidental to the business, is regarded as profits from that operation and excluded from separate interest provisions.
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.
International traffic profits taxed only in the enterprise's resident state, including container rentals and incidental interest treatment.
Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's State of residence; this includes transport receipts for passengers, goods, mail and livestock, participation in pools, joint businesses and international operating agencies. Income from use or rental of containers and related transport equipment used by the enterprise in international traffic is taxable only in the resident State unless such equipment is used solely within the other Contracting State. Interest directly connected with operation, if incidental to the business, is regarded as profits from that operation and excluded from separate interest provisions.
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