Tax exemption on bilateral shipping freight limited to service between the two countries; third-country carriage remains taxable. Article grants mutual exemption from income-tax on freight earnings of the other country's ships 'of this service', including time chartered ships, but confines the exemption to carriage between the ports of the two contracting countries; freight earnings from carriage involving third countries are taxable, and the interpretation is to be applied prospectively while past assessments will not be reopened for now.
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.
Tax exemption on bilateral shipping freight limited to service between the two countries; third-country carriage remains taxable.
Article grants mutual exemption from income-tax on freight earnings of the other country's ships "of this service", including time chartered ships, but confines the exemption to carriage between the ports of the two contracting countries; freight earnings from carriage involving third countries are taxable, and the interpretation is to be applied prospectively while past assessments will not be reopened for now.
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