Air transport profits taxable only in the enterprise's state; related participation and interest treated as air transport income. Profits from operating aircraft in international traffic are taxable only in the state of the enterprise, including profits from participation in pools, joint businesses or international operating agencies; this applies to the Scandinavian Airlines System consortium only to the extent of the Danish partner's share. Interest connected with aircraft operations is regarded as profits from such operations and treated accordingly. 'Operation of aircraft' includes transport of passengers, mail, livestock or goods by owners, lessees or charterers, ticket sales for others, incidental 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.
Air transport profits taxable only in the enterprise's state; related participation and interest treated as air transport income.
Profits from operating aircraft in international traffic are taxable only in the state of the enterprise, including profits from participation in pools, joint businesses or international operating agencies; this applies to the Scandinavian Airlines System consortium only to the extent of the Danish partner's share. Interest connected with aircraft operations is regarded as profits from such operations and treated accordingly. "Operation of aircraft" includes transport of passengers, mail, livestock or goods by owners, lessees or charterers, ticket sales for others, incidental leases and other activities directly connected with such transportation.
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