Shipping and air transport profits taxable only in the resident State, including related container income and connected interest. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; container use, maintenance or rental income used in international traffic is similarly taxable only in the resident State unless containers are used solely in the other State; interest directly connected with such operations is treated as operation profits and not governed by the separate interest provision; the same exclusive taxing rule applies to 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 taxable only in the resident State, including related container income and connected interest.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; container use, maintenance or rental income used in international traffic is similarly taxable only in the resident State unless containers are used solely in the other State; interest directly connected with such operations is treated as operation profits and not governed by the separate interest provision; the same exclusive taxing rule applies to participation in pools, joint businesses and international operating agencies.
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