Taxation of shipping and air transport restricted to the enterprise's state of residence with special rules for onboard management. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State of residence; this includes carriage of passengers, livestock or goods, income from containers, and incidental interest related to such operations for which Article 11 does not apply. If an enterprise's place of effective management is aboard a ship, it is deemed located in the State of the ship's home harbour or, if none, the State of the operator's residence. The exclusive taxation rule also covers participation in pools, joint businesses and international operating agencies.
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 restricted to the enterprise's state of residence with special rules for onboard management.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State of residence; this includes carriage of passengers, livestock or goods, income from containers, and incidental interest related to such operations for which Article 11 does not apply. If an enterprise's place of effective management is aboard a ship, it is deemed located in the State of the ship's home harbour or, if none, the State of the operator's residence. The exclusive taxation rule also covers participation in pools, joint businesses and international operating agencies.
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