Shipping profits allocation: exclusive residence taxation with a limited transitional source state taxing allowance. Profits from operating ships in international traffic are taxable only in the Contracting State where the enterprise is resident, subject to a limited transitional allowance for taxation by the source state for specified initial fiscal years. The rule also covers profits from participation in pools, joint businesses or international operating agencies engaged in ship operation, and interest connected with ship operation is treated as shipping profits, excluding the application of Article 12 to that interest.
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.
Shipping profits allocation: exclusive residence taxation with a limited transitional source state taxing allowance.
Profits from operating ships in international traffic are taxable only in the Contracting State where the enterprise is resident, subject to a limited transitional allowance for taxation by the source state for specified initial fiscal years. The rule also covers profits from participation in pools, joint businesses or international operating agencies engaged in ship operation, and interest connected with ship operation is treated as shipping profits, excluding the application of Article 12 to that interest.
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