Shipping profits taxable at place of effective management; other state may tax certain port-to-third-country voyages with reduced tax. Profits from the operation of ships in international traffic are taxable only in the Contracting State where the enterprise's place of effective ... Summary
Shipping profits taxable at place of effective management; other state may tax certain port-to-third-country voyages with reduced tax.
Profits from the operation of ships in international traffic are taxable only in the Contracting State where the enterprise's place of effective management is situated; if that place is aboard a ship it is treated as located in the State of the home harbour or, lacking a home harbour, the State of the operator's residence. This rule also covers participation in pools, joint businesses and international operating agencies. Income from voyages between a Contracting State's ports and third-country ports may be taxed by the other Contracting State, but the tax so imposed is subject to a reduction equal to half of that tax.
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