Taxation of shipping profits: residence-based rule with temporary limited source taxing rights that phase out to residence-exclusive taxation. Profits from operating ships in international traffic are taxable only in the Contracting State of the enterprise's place of effective management, though the other Contracting State may temporarily impose limited taxation during an initial transitional period; this rule also covers participation in pools, joint businesses and international operating agencies. Interest linked to ship operations is treated as shipping income and Article 12 does not apply, and profits include income from use, maintenance or rental of containers and related equipment used in international transport.
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 shipping profits: residence-based rule with temporary limited source taxing rights that phase out to residence-exclusive taxation.
Profits from operating ships in international traffic are taxable only in the Contracting State of the enterprise's place of effective management, though the other Contracting State may temporarily impose limited taxation during an initial transitional period; this rule also covers participation in pools, joint businesses and international operating agencies. Interest linked to ship operations is treated as shipping income and Article 12 does not apply, and profits include income from use, maintenance or rental of containers and related equipment used in international transport.
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