Taxation of shipping profits limited to state of effective management; excludes coastal traffic and covers pool participation. Profits from operation of ships in international traffic are taxable only in the Contracting State of the enterprise's place of effective management; this rule also covers profit shares from participation in pools, joint businesses or international operating agencies, but excludes profits arising from coastal 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 limited to state of effective management; excludes coastal traffic and covers pool participation.
Profits from operation of ships in international traffic are taxable only in the Contracting State of the enterprise's place of effective management; this rule also covers profit shares from participation in pools, joint businesses or international operating agencies, but excludes profits arising from coastal traffic.
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