Taxation of shipping profits: primary taxing right in the enterprise's state, limited secondary tax where operations occur. Profits from operation of ships in international traffic are taxable only in the enterprise's Contracting State, subject to an allowance for the State where operations are carried on to impose a secondary tax capped at one half of its otherwise applicable domestic tax; these rules also apply to profits from participation in a pool, joint business or international operating agency.
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 profits: primary taxing right in the enterprise's state, limited secondary tax where operations occur.
Profits from operation of ships in international traffic are taxable only in the enterprise's Contracting State, subject to an allowance for the State where operations are carried on to impose a secondary tax capped at one half of its otherwise applicable domestic tax; these rules also apply to profits from participation in a pool, joint business or international operating agency.
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