Air transport income taxable only in home state; ship transport income may be taxed abroad with reduced tax. Article 8 provides that aircraft operation income in international traffic is taxable only in the enterprise's Contracting State, while ship operation income may be taxed in the other Contracting State with a statutory reduction. The provision also covers pools, joint businesses and international operating agencies; treats interest on funds connected with such operations as operational income; and defines operation to include transport of persons, mail, livestock or goods, incidental leasing, and activities directly connected with 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.
Air transport income taxable only in home state; ship transport income may be taxed abroad with reduced tax.
Article 8 provides that aircraft operation income in international traffic is taxable only in the enterprise's Contracting State, while ship operation income may be taxed in the other Contracting State with a statutory reduction. The provision also covers pools, joint businesses and international operating agencies; treats interest on funds connected with such operations as operational income; and defines operation to include transport of persons, mail, livestock or goods, incidental leasing, and activities directly connected with transportation.
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