Taxation of shipping and air transport profits confined to the enterprise's State, including incidental rental and interest. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; included are bareboat rental ... Summary
Taxation of shipping and air transport profits confined to the enterprise's State, including incidental rental and interest.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; included are bareboat rental income, incidental container and equipment rental, interest directly connected and incidental to operations (excluded from Article 11), and income from participation in pools or joint operating agencies, with special rules on place of effective management aboard a ship and supersession of the prior air-transport agreement.
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