Taxation of international shipping profits confined to the enterprise's resident State, with special rules for containers and related interest. Profits from operating ships or aircraft in international traffic by a resident enterprise are taxable only in the resident State; the same applies to profits from use, maintenance or rental of containers used in international traffic unless used solely within the other State. Interest directly connected with such operations is treated as operational profits and excluded from separate interest rules, and participation in pools, joint businesses or international operating agencies is likewise covered by the exclusive residence taxation rule.
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 profits confined to the enterprise's resident State, with special rules for containers and related interest.
Profits from operating ships or aircraft in international traffic by a resident enterprise are taxable only in the resident State; the same applies to profits from use, maintenance or rental of containers used in international traffic unless used solely within the other State. Interest directly connected with such operations is treated as operational profits and excluded from separate interest rules, and participation in pools, joint businesses or international operating agencies is likewise covered by the exclusive residence taxation rule.
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