Taxation of air transport profits limited to the enterprise's contracting state; related interest is treated as transport income. Profits from operating aircraft in international traffic are taxable only in the enterprise's Contracting State; this exclusivity also applies to participation in pools, joint businesses or international operating agencies. Interest connected with aircraft operations is treated as profits from such operations and excluded from separate interest rules. 'Operation of aircraft' includes carriage of passengers, mail, livestock or goods by owners, lessees or charterers, sale of tickets on behalf of others, incidental aircraft leases and other activities directly connected with such 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 air transport profits limited to the enterprise's contracting state; related interest is treated as transport income.
Profits from operating aircraft in international traffic are taxable only in the enterprise's Contracting State; this exclusivity also applies to participation in pools, joint businesses or international operating agencies. Interest connected with aircraft operations is treated as profits from such operations and excluded from separate interest rules. "Operation of aircraft" includes carriage of passengers, mail, livestock or goods by owners, lessees or charterers, sale of tickets on behalf of others, incidental aircraft leases and other activities directly connected with such transportation.
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