Shipping income exemption prevents taxation by the other Contracting State unless vessels operate mainly within that State. Income derived from the operation of ships by an enterprise of one Contracting State is generally exempt from taxation in the other Contracting State unless the ships are operated wholly or mainly between places within that other Contracting State, creating a territorial nexus condition for source-state taxing rights.
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Provisions expressly mentioned in the judgment/order text.
Shipping income exemption prevents taxation by the other Contracting State unless vessels operate mainly within that State.
Income derived from the operation of ships by an enterprise of one Contracting State is generally exempt from taxation in the other Contracting State unless the ships are operated wholly or mainly between places within that other Contracting State, creating a territorial nexus condition for source-state taxing rights.
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