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Tax exemption for international air transport profits prevents the other State from taxing such enterprise income. Profits from the operation of aircraft in international traffic by an enterprise of one Contracting State shall not be taxed in the other Contracting State; this rule applies to participation in pools and to activities directly connected with such transportation, including ticket sales and incidental charter leases. Gains from the alienation of aircraft owned and operated by the enterprise, the income from which is taxable only in that State, shall be taxed only in that State.
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Provisions expressly mentioned in the judgment/order text.
Tax exemption for international air transport profits prevents the other State from taxing such enterprise income.
Profits from the operation of aircraft in international traffic by an enterprise of one Contracting State shall not be taxed in the other Contracting State; this rule applies to participation in pools and to activities directly connected with such transportation, including ticket sales and incidental charter leases. Gains from the alienation of aircraft owned and operated by the enterprise, the income from which is taxable only in that State, shall be taxed only in that State.
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