Shipping and Air Transport profits taxed exclusively in the enterprise's state of residence, with special rules for shipboard management. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State of residence; place of effective management aboard a ship is located in the state of the ship's home harbor or, absent a home harbor, the operator's residence. Income from use, maintenance or rental of containers used in international traffic is taxable only in the resident Contracting State unless containers are used solely within the other Contracting State. Paragraph one's exclusive taxation rule also applies to 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.
Shipping and Air Transport profits taxed exclusively in the enterprise's state of residence, with special rules for shipboard management.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State of residence; place of effective management aboard a ship is located in the state of the ship's home harbor or, absent a home harbor, the operator's residence. Income from use, maintenance or rental of containers used in international traffic is taxable only in the resident Contracting State unless containers are used solely within the other Contracting State. Paragraph one's exclusive taxation rule also applies to pools, joint businesses and international operating agencies.
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