Taxation of air transport: profits from international aircraft operations taxable only in the enterprise's State, including related interest. Profits from the operation of aircraft in international traffic are taxable only in the enterprise's State, including profits from participation in pools, joint businesses or international operating agencies; interest connected with such operations is treated as income from the operation and Article 11 does not apply. The operation of aircraft includes transportation of passengers, mail, livestock or goods, sale of tickets on behalf of others, incidental leases and other activities directly connected with such transportation.
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 air transport: profits from international aircraft operations taxable only in the enterprise's State, including related interest.
Profits from the operation of aircraft in international traffic are taxable only in the enterprise's State, including profits from participation in pools, joint businesses or international operating agencies; interest connected with such operations is treated as income from the operation and Article 11 does not apply. The operation of aircraft includes transportation of passengers, mail, livestock or goods, sale of tickets on behalf of others, incidental leases and other activities directly connected with such transportation.
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