Taxation of international transport profits: enterprise profits from aircraft and motor vehicle operations taxed in the contracting state. Profits from operation of aircraft or motor vehicles in international traffic are taxable in the Contracting State of the enterprise, including profits from pools, joint businesses and international operating agencies. Interest connected with such operations is treated as operation profits and Article 11 does not apply. 'Operation of aircraft' includes transportation of passengers, mail, livestock or goods, ticket sales on behalf of others, incidental leases and other directly connected activities. Profits from operation of ships are taxable under the Contracting State's domestic law.
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Provisions expressly mentioned in the judgment/order text.
Taxation of international transport profits: enterprise profits from aircraft and motor vehicle operations taxed in the contracting state.
Profits from operation of aircraft or motor vehicles in international traffic are taxable in the Contracting State of the enterprise, including profits from pools, joint businesses and international operating agencies. Interest connected with such operations is treated as operation profits and Article 11 does not apply. "Operation of aircraft" includes transportation of passengers, mail, livestock or goods, ticket sales on behalf of others, incidental leases and other directly connected activities. Profits from operation of ships are taxable under the Contracting State's domestic law.
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