Taxation of shipping and air transport profits confined to the enterprise's residence state, excluding source-state taxation in international traffic. Profits from operation of ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State, including revenue from carriage of passengers, mail, livestock or goods and related activities such as ticket sales, directly connected services, incidental rental, and participation in pools or joint businesses. Profits from use, maintenance or rental of containers used in such operations are similarly taxable only in the residence State; interest connected with operation funds is treated as operational profits, and gains on alienation of ships, aircraft or containers used in international traffic are taxable only in that State.
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.
Taxation of shipping and air transport profits confined to the enterprise's residence state, excluding source-state taxation in international traffic.
Profits from operation of ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State, including revenue from carriage of passengers, mail, livestock or goods and related activities such as ticket sales, directly connected services, incidental rental, and participation in pools or joint businesses. Profits from use, maintenance or rental of containers used in such operations are similarly taxable only in the residence State; interest connected with operation funds is treated as operational profits, and gains on alienation of ships, aircraft or containers used in international traffic are taxable only in that State.
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