Taxation of international air transport profits limited to the enterprise's place of effective management under the treaty. Profits from operating aircraft in international traffic are taxable only in the Contracting State of the enterprise's place of effective management, including shares of profits from pools, joint businesses or international operating agencies. Interest connected with such operation is treated as operational profit and excluded from application of other income provisions. 'Operation of aircraft' encompasses carriage of persons, luggage, livestock, goods or mail by carriers, lessees or charterers, sale of tickets on behalf of other enterprises, incidental leasing and other activities directly connected with that transportation.
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 international air transport profits limited to the enterprise's place of effective management under the treaty.
Profits from operating aircraft in international traffic are taxable only in the Contracting State of the enterprise's place of effective management, including shares of profits from pools, joint businesses or international operating agencies. Interest connected with such operation is treated as operational profit and excluded from application of other income provisions. "Operation of aircraft" encompasses carriage of persons, luggage, livestock, goods or mail by carriers, lessees or charterers, sale of tickets on behalf of other enterprises, incidental leasing and other activities directly connected with that transportation.
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