Taxation of international shipping and air transport: profits from operation of ships or aircraft taxable only in the enterprise's State. Profits from operation of aircraft or ships in international traffic are taxable only in the enterprise's Contracting State, including profits from participation in pools, joint businesses or international operating agencies; interest connected with such operations is treated as profits from those operations and Article 11 on interest does not apply. Profits include transportation of passengers, mail, livestock and goods by owners, lessees or charterers and encompass ticket sales on behalf of others, bareboat rental, and use, maintenance or rental of containers and related equipment.
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 and air transport: profits from operation of ships or aircraft taxable only in the enterprise's State.
Profits from operation of aircraft or ships in international traffic are taxable only in the enterprise's Contracting State, including profits from participation in pools, joint businesses or international operating agencies; interest connected with such operations is treated as profits from those operations and Article 11 on interest does not apply. Profits include transportation of passengers, mail, livestock and goods by owners, lessees or charterers and encompass ticket sales on behalf of others, bareboat rental, and use, maintenance or rental of containers and related equipment.
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