Taxation of international air transport: profits taxed only in the state of effective management, including pooled operations. Profits from operating aircraft in international traffic are taxable only in the Contracting State of the enterprise's place of effective management; this rule covers shares of profits from pooled services, joint air transport operations, and international operating agencies. Interest directly connected with such operations is treated as income from those operations and is not subject to the separate provision on interest.
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 air transport: profits taxed only in the state of effective management, including pooled operations.
Profits from operating aircraft in international traffic are taxable only in the Contracting State of the enterprise's place of effective management; this rule covers shares of profits from pooled services, joint air transport operations, and international operating agencies. Interest directly connected with such operations is treated as income from those operations and is not subject to the separate provision on interest.
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