Shipping profits taxation: primary taxing right for the enterprise's state, limited secondary tax right for the other state. Profits from operating ships in international traffic are taxable only in the enterprise's Contracting State, though the other Contracting State may tax such profits to a limited extent subject to a cap. The rule likewise applies to participation in pools, joint businesses and international operating agencies, and includes profits from use, maintenance or rental of containers and related equipment when used in international traffic.
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 profits taxation: primary taxing right for the enterprise's state, limited secondary tax right for the other state.
Profits from operating ships in international traffic are taxable only in the enterprise's Contracting State, though the other Contracting State may tax such profits to a limited extent subject to a cap. The rule likewise applies to participation in pools, joint businesses and international operating agencies, and includes profits from use, maintenance or rental of containers and related equipment when used in international traffic.
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