Taxation of shipping profits: residence taxation prevails, other State may tax limitedly on local shipping gross receipts. Profits from operation of ships in international traffic are taxable primarily only in the enterprise's State, but may also be taxed in the other Contracting State where shipping activities are carried on, subject to a cap. The rule applies to participation in pools, joint businesses and international operating agencies. The gross amount payable in the Contracting State comprises receipts for carriage at its ports, interest on funds connected with ship operations arising in that State, and amounts for use, maintenance or rental of containers and related equipment. Interest so specified is not governed by Article 12. No deduction is allowed for prior loss or depreciation allowances when that State determines taxable income.
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 shipping profits: residence taxation prevails, other State may tax limitedly on local shipping gross receipts.
Profits from operation of ships in international traffic are taxable primarily only in the enterprise's State, but may also be taxed in the other Contracting State where shipping activities are carried on, subject to a cap. The rule applies to participation in pools, joint businesses and international operating agencies. The gross amount payable in the Contracting State comprises receipts for carriage at its ports, interest on funds connected with ship operations arising in that State, and amounts for use, maintenance or rental of containers and related equipment. Interest so specified is not governed by Article 12. No deduction is allowed for prior loss or depreciation allowances when that State determines taxable income.
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