Avoidance of double taxation for shipping income: treaty exempts port to port cargo income and limits tax on third country carriage. The agreement provides that income derived by shipping companies from carriage of cargo between the Parties' ports shall not be taxed by the port-State, while income from carriage to third countries may be taxed by the port-State but with the tax reduced by an amount equal to two thirds; the Central Government has directed that this Article be given effect domestically under enabling statutory powers to implement the treaty.
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Provisions expressly mentioned in the judgment/order text.
Avoidance of double taxation for shipping income: treaty exempts port to port cargo income and limits tax on third country carriage.
The agreement provides that income derived by shipping companies from carriage of cargo between the Parties' ports shall not be taxed by the port-State, while income from carriage to third countries may be taxed by the port-State but with the tax reduced by an amount equal to two thirds; the Central Government has directed that this Article be given effect domestically under enabling statutory powers to implement the treaty.
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