Shipping profits allocation: exclusive taxation in the enterprise's Contracting State, with limited source-state taxation during transition. Profits from operating ships in international traffic are taxable only in the enterprise's Contracting State, subject to a transitional limited right of the other Contracting State to tax such profits for specified fiscal years. The rule also covers profits from participation in pools, joint businesses or international operating agencies, and treats interest connected with ship operations as shipping profits excluded from Article 12.
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 taxation in the enterprise's Contracting State, with limited source-state taxation during transition.
Profits from operating ships in international traffic are taxable only in the enterprise's Contracting State, subject to a transitional limited right of the other Contracting State to tax such profits for specified fiscal years. The rule also covers profits from participation in pools, joint businesses or international operating agencies, and treats interest connected with ship operations as shipping profits excluded from Article 12.
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