International traffic profits taxable only in the enterprise's resident state, covering containers, interest and pool participation. Profits from operating aircraft in international traffic are taxable only in the enterprise's resident Contracting State. Profits from use, maintenance, or rental of containers used in international traffic are also taxable only in the resident State unless containers are used solely within the other State. Interest connected with aircraft operations is regarded as profits from those operations and is excluded from the separate interest provisions. The rule in paragraph one extends to participation in pools, joint businesses and international operating agencies.
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.
International traffic profits taxable only in the enterprise's resident state, covering containers, interest and pool participation.
Profits from operating aircraft in international traffic are taxable only in the enterprise's resident Contracting State. Profits from use, maintenance, or rental of containers used in international traffic are also taxable only in the resident State unless containers are used solely within the other State. Interest connected with aircraft operations is regarded as profits from those operations and is excluded from the separate interest provisions. The rule in paragraph one extends to participation in pools, joint businesses and international operating agencies.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
