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        DTAA

        Article 8 - Shipping and air transport

        Saudi Arabia

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        Taxation of international transport: profits from operation of ships or aircraft taxable only in the enterprise's State of residence. Profits from operation of ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise; this rule includes use or rental of containers and related equipment and applies to participation in pools, joint businesses, and international operating agencies. If a shipping enterprise's place of effective management is aboard a ship, it is deemed situated in the State of the ship's home harbor or, lacking a home harbor, in the State of residence of the operator. Existing reciprocal exemptions for specified air transport enterprises remain unaffected.
                          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: profits from operation of ships or aircraft taxable only in the enterprise's State of residence.

                                Profits from operation of ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise; this rule includes use or rental of containers and related equipment and applies to participation in pools, joint businesses, and international operating agencies. If a shipping enterprise's place of effective management is aboard a ship, it is deemed situated in the State of the ship's home harbor or, lacking a home harbor, in the State of residence of the operator. Existing reciprocal exemptions for specified air transport enterprises remain unaffected.


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