Taxation of international shipping and air transport: residence-State rule with UN alternative permitting local taxation for substantial shipping activity. Profits from operation of ships and aircraft in international traffic are generally taxable only in the enterprise's State of residence under the OECD Model, including profits from pools, joint businesses and international operating agencies. The UN Model provides Alternative A which mirrors the OECD approach, and Alternative B which allows the other Contracting State to tax shipping profits when its shipping activities are more than casual, with profits allocated appropriately and reduced by a negotiated percentage. Domestic law may set special computation rules for non-resident shipping and air transport enterprises.
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Taxation of international shipping and air transport: residence-State rule with UN alternative permitting local taxation for substantial shipping activity.
Profits from operation of ships and aircraft in international traffic are generally taxable only in the enterprise's State of residence under the OECD Model, including profits from pools, joint businesses and international operating agencies. The UN Model provides Alternative A which mirrors the OECD approach, and Alternative B which allows the other Contracting State to tax shipping profits when its shipping activities are more than casual, with profits allocated appropriately and reduced by a negotiated percentage. Domestic law may set special computation rules for non-resident shipping and air transport enterprises.
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