Shipping and air transport profits taxable only in the enterprise's State; container income confined to resident State unless used solely abroad. Profits from operation of ships and aircraft in international traffic are taxable only in the enterprise's Contracting State of residence. Income from use, maintenance or rental of containers used for international transport is taxable only in the resident State unless the containers are used solely within the other Contracting State. Profits from participation in a pool, joint business or international operating agency are treated under the same exclusive allocation rule.
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.
Shipping and air transport profits taxable only in the enterprise's State; container income confined to resident State unless used solely abroad.
Profits from operation of ships and aircraft in international traffic are taxable only in the enterprise's Contracting State of residence. Income from use, maintenance or rental of containers used for international transport is taxable only in the resident State unless the containers are used solely within the other Contracting State. Profits from participation in a pool, joint business or international operating agency are treated under the same exclusive allocation rule.
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 
