Taxation of international shipping and air transport: profits and operationally connected interest taxed only in the enterprise's State. Profits from the operation of ships or aircraft in international traffic are taxable only in the State of the enterprise, including income from carriage of passengers, mail, livestock and goods, ticket sales on behalf of others, activities directly connected with transportation, rental incidental to such activities, use or rental of containers and related equipment, and participation in pools, joint businesses or international operating agencies; interest on funds connected with such operations is treated as operational profit and is excluded from Article 11.
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 and air transport: profits and operationally connected interest taxed only in the enterprise's State.
Profits from the operation of ships or aircraft in international traffic are taxable only in the State of the enterprise, including income from carriage of passengers, mail, livestock and goods, ticket sales on behalf of others, activities directly connected with transportation, rental incidental to such activities, use or rental of containers and related equipment, and participation in pools, joint businesses or international operating agencies; interest on funds connected with such operations is treated as operational profit and is excluded from Article 11.
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