Avoidance of double taxation exempts income from international air transport in one Contracting State from tax in the other. The Agreement provides that income derived by an enterprise of one Contracting State from operation of aircraft in international traffic shall be exempted from tax in the other Contracting State, extending the exemption to participation in pools, joint airline businesses, international operating agencies, and interest on funds directly connected with such operations; it preserves national assessment rules except where overridden by the Agreement and establishes a Mutual Agreement Procedure, entry into force notifications, effectivity by fiscal year, and termination mechanics.
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Provisions expressly mentioned in the judgment/order text.
Avoidance of double taxation exempts income from international air transport in one Contracting State from tax in the other.
The Agreement provides that income derived by an enterprise of one Contracting State from operation of aircraft in international traffic shall be exempted from tax in the other Contracting State, extending the exemption to participation in pools, joint airline businesses, international operating agencies, and interest on funds directly connected with such operations; it preserves national assessment rules except where overridden by the Agreement and establishes a Mutual Agreement Procedure, entry into force notifications, effectivity by fiscal year, and termination mechanics.
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