Profits from operation of ships or aircraft taxable only in the state of the enterprise for international traffic. Profits derived by an enterprise from the operation of ships or aircraft in international traffic are taxable only in the State of which the enterprise is a resident; this rule covers participation in pools, joint businesses and international operating agencies, treats interest connected with such operations as operational profits excluded from the separate interest article, and defines operation to include transportation of passengers, mail, livestock or goods, ticket sales, incidental leasing and other directly connected activities.
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.
Profits from operation of ships or aircraft taxable only in the state of the enterprise for international traffic.
Profits derived by an enterprise from the operation of ships or aircraft in international traffic are taxable only in the State of which the enterprise is a resident; this rule covers participation in pools, joint businesses and international operating agencies, treats interest connected with such operations as operational profits excluded from the separate interest article, and defines operation to include transportation of passengers, mail, livestock or goods, ticket sales, incidental leasing and other directly connected activities.
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