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        DTAA

        Article 9 - Shipping

        Italy
        Chapter III
        TAXATION OF INCOME

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        Taxation of shipping income confined to the enterprise's state, with connected interest and incidental rentals governed accordingly. Income from operation of ships in international traffic is taxable only in the enterprise's Contracting State; this includes profits from participation in pools, joint businesses or international operating agencies. Interest connected with ship operation is regarded as shipping income and Article 12 does not apply. Shipping income also covers rentals of ships on a full or bareboat basis when incidental to international operation and profits from use, maintenance or rental of containers; coastal traffic profits are excluded from paragraph 1.
                          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 income confined to the enterprise's state, with connected interest and incidental rentals governed accordingly.

                                Income from operation of ships in international traffic is taxable only in the enterprise's Contracting State; this includes profits from participation in pools, joint businesses or international operating agencies. Interest connected with ship operation is regarded as shipping income and Article 12 does not apply. Shipping income also covers rentals of ships on a full or bareboat basis when incidental to international operation and profits from use, maintenance or rental of containers; coastal traffic profits are excluded from paragraph 1.


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