Air transport profits taxable only in the enterprise's state, including pools, joint businesses and related aviation operations. Profits from the operation of aircraft by an enterprise of a Contracting State are taxable only in that State; this rule also covers profits from participation in a pool, a joint business or an international operating agency. 'Operation of aircraft' includes transportation of passengers, mail, livestock or goods, sale of tickets on behalf of other enterprises, incidental leases and any activity 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.
Air transport profits taxable only in the enterprise's state, including pools, joint businesses and related aviation operations.
Profits from the operation of aircraft by an enterprise of a Contracting State are taxable only in that State; this rule also covers profits from participation in a pool, a joint business or an international operating agency. "Operation of aircraft" includes transportation of passengers, mail, livestock or goods, sale of tickets on behalf of other enterprises, incidental leases and any activity directly connected with such transportation.
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