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 ... Summary
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.
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