Taxation of international air transport profits limited to the enterprise's state; related interest treated as operational profits. Profits from the operation of aircraft in international traffic are taxable only in the State of the enterprise. This rule also covers profits from participation in pools, joint businesses or international operating agencies, and applies to SAS only insofar as profits attributable to DNL correspond to its share. Interest connected with aircraft operations is regarded as operational profits and Article 12 does not apply. 'Operation of aircraft' includes carriage of passengers, mail, livestock or goods, ticket sales, incidental leases and other directly connected activities.
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 limited to the enterprise's state; related interest treated as operational profits.
Profits from the operation of aircraft in international traffic are taxable only in the State of the enterprise. This rule also covers profits from participation in pools, joint businesses or international operating agencies, and applies to SAS only insofar as profits attributable to DNL correspond to its share. Interest connected with aircraft operations is regarded as operational profits and Article 12 does not apply. "Operation of aircraft" includes carriage of passengers, mail, livestock or goods, ticket sales, incidental leases and other directly connected activities.
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