Taxation of international transport income rests with the enterprise's residence state, with limited source-state taxing power reduced by treaty. Article 8 allocates taxation of income from international transport to the enterprise's Contracting State for operation or rental of ships or aircraft, and incidental rental of containers and related equipment; it extends to pools, joint businesses and international operating agencies. Interest directly connected to such operations is treated as transport income and excluded from separate interest rules, while income from carriage between the other State's ports and third-country ports may be taxed by that other State subject to a statutory reduction.
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 transport income rests with the enterprise's residence state, with limited source-state taxing power reduced by treaty.
Article 8 allocates taxation of income from international transport to the enterprise's Contracting State for operation or rental of ships or aircraft, and incidental rental of containers and related equipment; it extends to pools, joint businesses and international operating agencies. Interest directly connected to such operations is treated as transport income and excluded from separate interest rules, while income from carriage between the other State's ports and third-country ports may be taxed by that other State subject to a statutory reduction.
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