Shipping and air transport profits taxed only in the enterprise's resident state; container and related interest treated similarly. Profits of a resident enterprise from operating ships or aircraft in international traffic are taxable only in the enterprise's State; this includes designated national transport enterprises. Container use, maintenance or rental profits are taxable only in the resident State unless containers are used solely within the other State. Interest directly connected with ship or aircraft operations is treated as operational profits and excluded from Article 11. The rule also covers 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.
Shipping and air transport profits taxed only in the enterprise's resident state; container and related interest treated similarly.
Profits of a resident enterprise from operating ships or aircraft in international traffic are taxable only in the enterprise's State; this includes designated national transport enterprises. Container use, maintenance or rental profits are taxable only in the resident State unless containers are used solely within the other State. Interest directly connected with ship or aircraft operations is treated as operational profits and excluded from Article 11. The rule also covers participation in pools, joint businesses and international operating agencies.
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