International shipping and air transport profits taxable only in the enterprise's state of residence, covering pools and consortia. Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State of which the enterprise is a resident; this rule covers participation in pools, joint businesses, international operating agencies and the resident company's share of consortium profits. 'Profits from international traffic' include revenues from transporting passengers, mail, livestock or goods by owners, lessees or charterers and related receipts such as ticket sales on behalf of others, incidental leases, and income from use, maintenance or rental of containers and related equipment. Interest accruing to a permanent establishment from such operations is likewise regarded as these profits, excluding investment interest.
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.
International shipping and air transport profits taxable only in the enterprise's state of residence, covering pools and consortia.
Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State of which the enterprise is a resident; this rule covers participation in pools, joint businesses, international operating agencies and the resident company's share of consortium profits. "Profits from international traffic" include revenues from transporting passengers, mail, livestock or goods by owners, lessees or charterers and related receipts such as ticket sales on behalf of others, incidental leases, and income from use, maintenance or rental of containers and related equipment. Interest accruing to a permanent establishment from such operations is likewise regarded as these profits, excluding investment interest.
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