Profits from international shipping and air transport taxable only in resident state; consortium shares treated proportionately. Profits from the operation of ships or aircraft in international traffic are taxable only in the State of residence of the enterprise, and this rule applies to participation in pools, joint businesses, international operating agencies and consortium arrangements in proportion to participation. 'Profits from the operation of ships or aircraft in international traffic' include receipts from transporting passengers, mail, livestock or goods, sale of tickets on behalf of others, incidental leases of vessels or aircraft, and use, maintenance or rental of containers; interest on funds generated by the operation and arising to a permanent establishment is treated as such operational profit, excluding interest on investment funds.
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.
Profits from international shipping and air transport taxable only in resident state; consortium shares treated proportionately.
Profits from the operation of ships or aircraft in international traffic are taxable only in the State of residence of the enterprise, and this rule applies to participation in pools, joint businesses, international operating agencies and consortium arrangements in proportion to participation. "Profits from the operation of ships or aircraft in international traffic" include receipts from transporting passengers, mail, livestock or goods, sale of tickets on behalf of others, incidental leases of vessels or aircraft, and use, maintenance or rental of containers; interest on funds generated by the operation and arising to a permanent establishment is treated as such operational profit, excluding interest on investment funds.
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