Taxation of international air transport profits allows source-state taxation with a constrained, reduced tax to limit double taxation. Profits from operating aircraft in international traffic are taxable in the enterprise's State of residence, while the source State may tax those profits under its domestic law subject to a specified reduction; the same rules apply to participation in pools, joint businesses or international operating agencies.
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Provisions expressly mentioned in the judgment/order text.
Taxation of international air transport profits allows source-state taxation with a constrained, reduced tax to limit double taxation.
Profits from operating aircraft in international traffic are taxable in the enterprise's State of residence, while the source State may tax those profits under its domestic law subject to a specified reduction; the same rules apply to participation in pools, joint businesses or international operating agencies.
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