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        DTAA

        Article 8 - Air Transport

        Netherlands
        Chapter III
        TAXATION OF INCOME

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        Taxation of international air transport profits confined to state of effective management, including related rentals and interest. Profits from operating aircraft in international traffic are taxable only in the State of the place of effective management; this includes incidental bareboat rental profits and interest on funds connected with such operations, with that interest treated as operational profits and not governed by the separate interest provision. The same exclusive taxing rule applies to profits from participation in a pool, joint business or international operating agency.
                          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 air transport profits confined to state of effective management, including related rentals and interest.

                              Profits from operating aircraft in international traffic are taxable only in the State of the place of effective management; this includes incidental bareboat rental profits and interest on funds connected with such operations, with that interest treated as operational profits and not governed by the separate interest provision. The same exclusive taxing rule applies to profits from participation in a pool, joint business or international operating agency.


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