Taxation of international air transport profits limited to the enterprise's contracting state, including associated interest and pool income. Profits from operating aircraft in international traffic are taxable only in the enterprise's Contracting State, including profits from participation in pools, joint businesses or international operating agencies. Interest connected with aircraft operations is treated as such profits and is not subject to separate interest provisions. 'Operation of aircraft' covers carriage of passengers, mail, livestock and goods, ticket sales on behalf of others, incidental aircraft leases and other activities directly connected with 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 international air transport profits limited to the enterprise's contracting state, including associated interest and pool income.
Profits from operating aircraft in international traffic are taxable only in the enterprise's Contracting State, including profits from participation in pools, joint businesses or international operating agencies. Interest connected with aircraft operations is treated as such profits and is not subject to separate interest provisions. "Operation of aircraft" covers carriage of passengers, mail, livestock and goods, ticket sales on behalf of others, incidental aircraft leases and other activities directly connected with transportation.
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