Shipping and transport taxation: profits from operation of ships or aircraft taxable only in the enterprise's resident State. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; this exclusive taxing right covers container use, maintenance or rental for international transport except where containers are used solely within the other State, treats interest connected with such operations as operational profits (excluding separate interest provisions), and applies to participation in pools, joint businesses, and international operating agencies.
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 transport taxation: profits from operation of ships or aircraft taxable only in the enterprise's resident State.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; this exclusive taxing right covers container use, maintenance or rental for international transport except where containers are used solely within the other State, treats interest connected with such operations as operational profits (excluding separate interest provisions), and applies to participation in pools, joint businesses, and international operating agencies.
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