Taxation of shipping profits: profits from ship operations taxable only in the enterprise's state, including container rentals. Profits from the operation of ships in international traffic are taxable only in the Contracting State of the enterprise; this rule also covers profits from participation in a pool, joint business or international operating agency engaged in ship operation, and expressly includes profits from the use, maintenance or rental of containers (including trailers and related equipment) in connection with transporting goods in international traffic.
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 profits: profits from ship operations taxable only in the enterprise's state, including container rentals.
Profits from the operation of ships in international traffic are taxable only in the Contracting State of the enterprise; this rule also covers profits from participation in a pool, joint business or international operating agency engaged in ship operation, and expressly includes profits from the use, maintenance or rental of containers (including trailers and related equipment) in connection with transporting goods in international traffic.
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