Taxation of international transport profits confined to the enterprise's state, including incidental container income and related interest. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; this includes incidental income from containers and interest on bank accounts (excluding term deposits) directly connected with those operations. The exclusive taxing right extends to profits from participation in pools, joint businesses and international operating agencies.
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 transport profits confined to the enterprise's state, including incidental container income and related interest.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; this includes incidental income from containers and interest on bank accounts (excluding term deposits) directly connected with those operations. The exclusive taxing right extends to profits from participation in pools, joint businesses and international operating agencies.
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