Taxation of international air transport: profits taxable only in the state of effective management; related interest treated as operational income. Profits from operating aircraft in international traffic are taxable only in the Contracting State of the enterprise's place of effective management. This rule covers shares of profits from pooled services, joint air transport operations, and international operation agencies. Interest on funds directly connected with such operations is treated as operational income and is subject to the same exclusivity, with other interest provisions inapplicable to that interest.
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 taxable only in the state of effective management; related interest treated as operational income.
Profits from operating aircraft in international traffic are taxable only in the Contracting State of the enterprise's place of effective management. This rule covers shares of profits from pooled services, joint air transport operations, and international operation agencies. Interest on funds directly connected with such operations is treated as operational income and is subject to the same exclusivity, with other interest provisions inapplicable to that interest.
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