Shipping income taxation confined to the contracting state, with exceptions for domestic voyages and container operations. Income from operation of ships in international traffic is taxable only in the enterprise's Contracting State, except for journeys between places in the other State. This treatment includes bareboat rental incidental to shipping operations and extends to use, maintenance or rental of containers and related equipment. Participation in pools, joint businesses or international operating agencies is covered, and gains on alienation of ships or containers are taxable only in the enterprise's State where operational income was so taxed or the assets were situated outside the other State at alienation.
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 income taxation confined to the contracting state, with exceptions for domestic voyages and container operations.
Income from operation of ships in international traffic is taxable only in the enterprise's Contracting State, except for journeys between places in the other State. This treatment includes bareboat rental incidental to shipping operations and extends to use, maintenance or rental of containers and related equipment. Participation in pools, joint businesses or international operating agencies is covered, and gains on alienation of ships or containers are taxable only in the enterprise's State where operational income was so taxed or the assets were situated outside the other State at alienation.
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