Taxation of shipping and air transport: profits from international carriage taxable only in the enterprise's Contracting State. Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise. This rule covers profits from participation in pools, joint businesses or international operating agencies; treats interest connected with such operations as profits from those operations (thus excluding Article 11); and defines such profits to include carriage of passengers, mail, livestock and goods and ancillary receipts from ticket sales, incidental leasing, container use/maintenance/rental 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 shipping and air transport: profits from international carriage taxable only in the enterprise's Contracting State.
Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise. This rule covers profits from participation in pools, joint businesses or international operating agencies; treats interest connected with such operations as profits from those operations (thus excluding Article 11); and defines such profits to include carriage of passengers, mail, livestock and goods and ancillary receipts from ticket sales, incidental leasing, container use/maintenance/rental and other activities directly connected with transportation.
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