Air transport income exempt from foreign taxation unless flights operate chiefly within that state; refund for designated carriers. Income from operation of aircraft by an enterprise of one Contracting State is not taxable in the other State unless the aircraft is operated wholly or mainly within that other State; this rule also covers participations in pools. A mutual understanding provides that, for specified prior years/accounting periods, taxes paid or payable by a designated airline of one State shall be refunded or not charged by the other State, with designated airlines identified for each Contracting State.
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 exempt from foreign taxation unless flights operate chiefly within that state; refund for designated carriers.
Income from operation of aircraft by an enterprise of one Contracting State is not taxable in the other State unless the aircraft is operated wholly or mainly within that other State; this rule also covers participations in pools. A mutual understanding provides that, for specified prior years/accounting periods, taxes paid or payable by a designated airline of one State shall be refunded or not charged by the other State, with designated airlines identified for each Contracting State.
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