Taxation of air transport profits limited to the State of operation for international traffic; related interest treated as operational income. Profits from operating aircraft in international traffic are taxable only in the Contracting State of operation, including profits from participation in pools, joint businesses or international operating agencies. Interest on funds connected with such operation is regarded as operational profits and is subject to the same taxation rule. 'Operation of aircraft' includes transport of passengers, mail, livestock and goods by owners, lessees or charterers, sale of tickets for others, incidental leasing and other activities directly connected with 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 State of operation for international traffic; related interest treated as operational income.
Profits from operating aircraft in international traffic are taxable only in the Contracting State of operation, including profits from participation in pools, joint businesses or international operating agencies. Interest on funds connected with such operation is regarded as operational profits and is subject to the same taxation rule. "Operation of aircraft" includes transport of passengers, mail, livestock and goods by owners, lessees or charterers, sale of tickets for others, incidental leasing and other activities directly connected with transportation.
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