Shipping profits in international traffic: source-state taxation with capped deemed profit and mandatory partial tax reduction on embarked carriage. Profits from operation of ships in international traffic may be taxed in each Contracting State; where profits arise from operations in the other State they shall be deemed not to exceed five per cent of the full amount received for carriage of passengers or freight embarked in that other State, and the tax chargeable in that other State shall be reduced by an amount equal to fifty per cent.
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.
Shipping profits in international traffic: source-state taxation with capped deemed profit and mandatory partial tax reduction on embarked carriage.
Profits from operation of ships in international traffic may be taxed in each Contracting State; where profits arise from operations in the other State they shall be deemed not to exceed five per cent of the full amount received for carriage of passengers or freight embarked in that other State, and the tax chargeable in that other State shall be reduced by an amount equal to fifty per cent.
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