Air transport profits taxation limited to state of an enterprise's place of effective management, covering pooled operations and related interest. Profits from operating aircraft in international traffic are taxable only in the Contracting State where the place of effective management of the enterprise is situated; this treatment also covers profits from pooled services, joint air transport operations and international operating agencies. Interest on funds connected with such operations is regarded as income from the operation and is not governed by separate interest provisions.
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.
Air transport profits taxation limited to state of an enterprise's place of effective management, covering pooled operations and related interest.
Profits from operating aircraft in international traffic are taxable only in the Contracting State where the place of effective management of the enterprise is situated; this treatment also covers profits from pooled services, joint air transport operations and international operating agencies. Interest on funds connected with such operations is regarded as income from the operation and is not governed by separate interest provisions.
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