Taxation of international air transport limited to the State of the enterprise, including pools and related operations. Profits from the operation of aircraft in international traffic carried on by an enterprise of a Contracting State are taxable only in that State, including profits from participation in pools, joint businesses or international operating agencies. 'Operation of aircraft' includes transportation of persons, livestock, goods or mail by owners, lessees or charterers, sale of tickets on behalf of other enterprises, incidental charter leases and other activities directly connected with such transportation.
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 limited to the State of the enterprise, including pools and related operations.
Profits from the operation of aircraft in international traffic carried on by an enterprise of a Contracting State are taxable only in that State, including profits from participation in pools, joint businesses or international operating agencies. "Operation of aircraft" includes transportation of persons, livestock, goods or mail by owners, lessees or charterers, sale of tickets on behalf of other enterprises, incidental charter leases and other activities directly connected with such transportation.
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