Shipping and air transport profits: exclusive taxing right in the enterprise's State, covering charters, containers, interest and pools. Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise. This includes profits from bare boat rentals and incidental container rentals. Interest connected with such operations is treated as operational profits and the separate interest rules do not apply. The rule also covers profits from participation in pools, joint businesses, or 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.
Shipping and air transport profits: exclusive taxing right in the enterprise's State, covering charters, containers, interest and pools.
Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise. This includes profits from bare boat rentals and incidental container rentals. Interest connected with such operations is treated as operational profits and the separate interest rules do not apply. The rule also covers profits from participation in pools, joint businesses, or international operating agencies.
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