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        DTAA

        Article 8 - International Shipping and Air Transport

        OECD Model (2017)
        Chapter III
        TAXATION OF INCOME

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        Taxation of international shipping income limited to the enterprise's residence state; applies to pools and joint operating agencies. Profits of an enterprise from operating ships or aircraft in international traffic are taxable only in the State of which the enterprise is a resident, and this rule also applies to profits from participation in a pool, a joint business or an international operating agency related to such international traffic.
                          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 shipping income limited to the enterprise's residence state; applies to pools and joint operating agencies.

                                Profits of an enterprise from operating ships or aircraft in international traffic are taxable only in the State of which the enterprise is a resident, and this rule also applies to profits from participation in a pool, a joint business or an international operating agency related to such international traffic.


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