International shipping and air transport profits taxable only in the enterprise's state; containers and incidental interest receive special tax treatment. Profits from operation of ships or aircraft in international traffic by an enterprise resident in a Contracting State are taxable only in that State, including profits from participation in pools, joint businesses, or international operating agencies. Profits from use, maintenance, or rental of containers used in international transport are also taxable only in the State of residence unless the containers are used solely within the other State. Interest earned incidentally on funds connected with such operations is treated as profits from those operations and not governed by the separate interest provision.
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.
International shipping and air transport profits taxable only in the enterprise's state; containers and incidental interest receive special tax treatment.
Profits from operation of ships or aircraft in international traffic by an enterprise resident in a Contracting State are taxable only in that State, including profits from participation in pools, joint businesses, or international operating agencies. Profits from use, maintenance, or rental of containers used in international transport are also taxable only in the State of residence unless the containers are used solely within the other State. Interest earned incidentally on funds connected with such operations is treated as profits from those operations and not governed by the separate interest provision.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
