Taxation of shipping and air transport profits: taxable only in the enterprise's residence; containers and incidental interest covered. Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; the same applies to profits ... Summary
Taxation of shipping and air transport profits: taxable only in the enterprise's residence; containers and incidental interest covered.
Profits from operation of ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; the same applies to profits from use, maintenance or rental of containers used in international traffic unless used solely within the other State. Interest directly connected and incidental to such operations is regarded as profits from those operations and Article 11 does not apply. Profits from participation in a pool, joint business or international operating agency fall under the same residence-state exclusivity.
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