Air transport taxation: exclusive taxing right for enterprise international aircraft profits, with limited transitional taxation for ships. Profits from operation of aircraft in international traffic by an enterprise of a Contracting State are taxable only in that Contracting State; profits from operation of ships are likewise taxable only in that Contracting State, subject to a transitional exception permitting the other Contracting State limited taxation during an initial period. These provisions extend to participation in a pool, joint business or international operating agency and apply to the enterprise tax in Japan and any similar tax in India.
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.
Air transport taxation: exclusive taxing right for enterprise international aircraft profits, with limited transitional taxation for ships.
Profits from operation of aircraft in international traffic by an enterprise of a Contracting State are taxable only in that Contracting State; profits from operation of ships are likewise taxable only in that Contracting State, subject to a transitional exception permitting the other Contracting State limited taxation during an initial period. These provisions extend to participation in a pool, joint business or international operating agency and apply to the enterprise tax in Japan and any similar tax in India.
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