Taxation of international air transport: profits from aircraft operations are taxable only in the enterprise's state of residence. Profits from the operation of aircraft in international traffic shall be taxable only in the Contracting State where the enterprise is resident; this exclusivity extends to participation in pools, joint businesses and international operating agencies. Interest connected with such operations is regarded as profits from the operation and article 12 does not apply. 'Operation of aircraft' encompasses air transport of passengers, mail, livestock or goods by owners, lessees or charterers, sale of tickets for others, incidental aircraft leases and other activities directly connected with the transportation.
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 from aircraft operations are taxable only in the enterprise's state of residence.
Profits from the operation of aircraft in international traffic shall be taxable only in the Contracting State where the enterprise is resident; this exclusivity extends to participation in pools, joint businesses and international operating agencies. Interest connected with such operations is regarded as profits from the operation and article 12 does not apply. "Operation of aircraft" encompasses air transport of passengers, mail, livestock or goods by owners, lessees or charterers, sale of tickets for others, incidental aircraft leases and other activities directly connected with the transportation.
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