Shipping and air transport profits taxable only in the enterprise's contracting state, including container and pooling arrangements. Profits from the operation of ships or aircraft in international traffic are taxable only in the enterprise's Contracting State, including profits from full and certain bareboat rentals, inland transport that forms part of international traffic, and profits from use, maintenance, or rental of containers, except where containers are used solely within the other Contracting State; the rule also applies to participation in pools, joint businesses, or 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.
Shipping and air transport profits taxable only in the enterprise's contracting state, including container and pooling arrangements.
Profits from the operation of ships or aircraft in international traffic are taxable only in the enterprise's Contracting State, including profits from full and certain bareboat rentals, inland transport that forms part of international traffic, and profits from use, maintenance, or rental of containers, except where containers are used solely within the other Contracting State; the rule also applies to participation in pools, joint businesses, or international operating agencies.
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