Taxation of international shipping profits confined to the enterprise's residence; Qatar may designate state-owned carriers. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's resident Contracting State; for Qatar this covers designated state-associated carriers while the State holds a share. The same exclusive residence taxation applies to participation in pools, joint businesses and international operating agencies. Income from use, maintenance or rental of containers used in international traffic is taxable only in the resident State unless containers are used solely within the other State. Interest connected with ship or aircraft operations is treated as operational profits and excluded from the treaty's separate interest provision.
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 shipping profits confined to the enterprise's residence; Qatar may designate state-owned carriers.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's resident Contracting State; for Qatar this covers designated state-associated carriers while the State holds a share. The same exclusive residence taxation applies to participation in pools, joint businesses and international operating agencies. Income from use, maintenance or rental of containers used in international traffic is taxable only in the resident State unless containers are used solely within the other State. Interest connected with ship or aircraft operations is treated as operational profits and excluded from the treaty's separate interest provision.
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 
