Tax exemption for international shipping and air transport income prevents taxation in the other contracting jurisdiction. Income from the operation of ships or aircraft in international traffic by an enterprise of one Contracting State shall not be taxed in the other Contracting State, including receipts from carriage of passengers, mail, livestock and goods, ticket sales, activities directly connected with transportation, and leasing of ships or aircraft when incidental to transportation; interest directly connected with such operations is treated as exempt transport income and there is no withholding tax. The provision also covers container use, maintenance or rental incidental to carriage and income from participation in pools, joint businesses, or international operating agencies.
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.
Tax exemption for international shipping and air transport income prevents taxation in the other contracting jurisdiction.
Income from the operation of ships or aircraft in international traffic by an enterprise of one Contracting State shall not be taxed in the other Contracting State, including receipts from carriage of passengers, mail, livestock and goods, ticket sales, activities directly connected with transportation, and leasing of ships or aircraft when incidental to transportation; interest directly connected with such operations is treated as exempt transport income and there is no withholding tax. The provision also covers container use, maintenance or rental incidental to carriage and income from participation in pools, joint businesses, or international operating agencies.
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