Shipping and air transport profits taxable only in the enterprise's state, covering operational, container and related interest income. Profits from operation of ships or aircraft in international traffic by an enterprise are taxable only in the enterprise's State; this includes ... Summary
Shipping and air transport profits taxable only in the enterprise's state, covering operational, container and related interest income.
Profits from operation of ships or aircraft in international traffic by an enterprise are taxable only in the enterprise's State; this includes carriage-related revenues (passengers, mail, livestock, goods), ticket sales on behalf of others, direct transport-related activities, incidental rental of ships or aircraft, and income from use, maintenance or rental of containers. The exclusive taxation rule extends to participation in pools, joint businesses and international operating agencies. Interest on funds connected with such operations is treated as operational profits and not subject to the separate interest provision.
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