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          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.

          <h1>Shipping profits from international traffic are taxable only in the contracting state, excluding separate treatment of related interest.</h1> Profits from operating ships in international traffic are taxable only in the enterprise's Contracting State, including profits from participation in pools, joint businesses or international operating agencies. Interest directly connected with ship operations is treated as shipping income and not subject to Article 12. The operation of ships covers sea transportation of passengers, mail, livestock or goods by owners, lessees or charterers, sale of tickets, incidental lease of ships on behalf of others, and other activities directly connected with such transportation.

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