Taxation of air transport profits limited to the enterprise's state of residence for international aircraft operations only. Profits from operating aircraft in international traffic are taxable only in the enterprise's Contracting State of residence; this exclusivity covers participation in pools, joint businesses or international operating agencies and includes interest on funds connected with aircraft operations, which is treated as operational profit. 'Operation of aircraft' includes air transportation of passengers, mail, livestock or goods by owners, lessees or charterers, ticket sales on behalf of others, incidental aircraft leasing and other activities 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.
Taxation of air transport profits limited to the enterprise's state of residence for international aircraft operations only.
Profits from operating aircraft in international traffic are taxable only in the enterprise's Contracting State of residence; this exclusivity covers participation in pools, joint businesses or international operating agencies and includes interest on funds connected with aircraft operations, which is treated as operational profit. "Operation of aircraft" includes air transportation of passengers, mail, livestock or goods by owners, lessees or charterers, ticket sales on behalf of others, incidental aircraft leasing and other activities directly connected with such transportation.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
