International transport profits receive exclusive taxation where effective management is located, including connected interest and pool participation. Profits from international ship or aircraft operations are taxable exclusively in the Contracting State where the enterprise's place of effective ... Summary
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International transport profits receive exclusive taxation where effective management is located, including connected interest and pool participation.
Profits from international ship or aircraft operations are taxable exclusively in the Contracting State where the enterprise's place of effective management is situated. Shipping enterprises managed aboard a ship are deemed managed in the State of the home harbour or, if none, the operator's State of residence. The rule extends to pools, joint businesses and international operating agencies. Connected interest is treated as operating profit, while covered operations include transportation, ticket sales, incidental leasing and directly connected activities.
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