Shipping and air transport profits taxable only in the operator's State, with related interest treated as operational income. Profits from operation of aircraft or ships in international traffic are taxable only in the Contracting State of the enterprise, including profits from participation in pools, joint businesses or international operating agencies; interest connected with such operation is treated as profits from that operation and Article 11 (Interest) does not apply. Profits include transport revenue, ticket sales for others, bareboat rentals, and use or rental of containers and related equipment in international transport.
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 air transport profits taxable only in the operator's State, with related interest treated as operational income.
Profits from operation of aircraft or ships in international traffic are taxable only in the Contracting State of the enterprise, including profits from participation in pools, joint businesses or international operating agencies; interest connected with such operation is treated as profits from that operation and Article 11 (Interest) does not apply. Profits include transport revenue, ticket sales for others, bareboat rentals, and use or rental of containers and related equipment in international transport.
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