Taxation of international shipping and air transport is limited to the State of effective management, including interest and pools. Profits from operating or chartering ships or aircraft in international traffic, and rental of containers incidental thereto, are taxable only in the Contracting State of the enterprise's place of effective management; if that place is aboard a vessel it is deemed to be in the State of the vessel's home harbour or the State of the operator's residence. Interest connected with such operations is treated as operational profits and excluded from separate interest provisions, and the exclusive taxation rule also covers 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.
Taxation of international shipping and air transport is limited to the State of effective management, including interest and pools.
Profits from operating or chartering ships or aircraft in international traffic, and rental of containers incidental thereto, are taxable only in the Contracting State of the enterprise's place of effective management; if that place is aboard a vessel it is deemed to be in the State of the vessel's home harbour or the State of the operator's residence. Interest connected with such operations is treated as operational profits and excluded from separate interest provisions, and the exclusive taxation rule also covers pools, joint businesses and international operating agencies.
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