Shipping and air transport taxation: residence-state exclusive taxation for profits from international operations and related container use. Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's residence State; this exclusive residence-state taxation also covers profits from use, maintenance or rental of containers used in international traffic unless they are used solely within the other Contracting State, and applies to participation in pools, joint businesses or international operating agencies. A pro rata rule limits the residence-state treatment for profits of the SAS consortium to the share attributable to the Swedish partner, SAS Sverige AB.
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Provisions expressly mentioned in the judgment/order text.
Shipping and air transport taxation: residence-state exclusive taxation for profits from international operations and related container use.
Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's residence State; this exclusive residence-state taxation also covers profits from use, maintenance or rental of containers used in international traffic unless they are used solely within the other Contracting State, and applies to participation in pools, joint businesses or international operating agencies. A pro rata rule limits the residence-state treatment for profits of the SAS consortium to the share attributable to the Swedish partner, SAS Sverige AB.
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