Shipping and air transport profits are taxable solely in the State of the enterprise, including related container and interest income. Profits from operation of ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State, including receipts from carriage, ticket sales for others, incidental rental, and interest on funds connected with such operations; income from use, maintenance or rental of containers and profits from participation in pools or joint businesses are similarly taxable only in the State of the enterprise, as are gains from alienation of ships, aircraft or containers owned and operated by the enterprise.
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 and air transport profits are taxable solely in the State of the enterprise, including related container and interest income.
Profits from operation of ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State, including receipts from carriage, ticket sales for others, incidental rental, and interest on funds connected with such operations; income from use, maintenance or rental of containers and profits from participation in pools or joint businesses are similarly taxable only in the State of the enterprise, as are gains from alienation of ships, aircraft or containers owned and operated by the enterprise.
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