https://www.taxtmi.com/acts?id=5387 Profits from operating ships in international traffic are taxable only in the enterprise's State of residence, though the State where the operation is carried on may tax those profits subject to a treaty cap. The rule also covers participation in pools, joint businesses and international operating agencies. Where an enterprise is carried on by partners with joint liability and residents in both Contracting States and management is not solely in one State, profits are apportioned and taxed in the partners' resident States. Container rental and related equipment income is included. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 05 Mar 2009 17:26:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5387 Profits from operating ships in international traffic are taxable only in the enterprise's State of residence, though the State where the operation is carried on may tax those profits subject to a treaty cap. The rule also covers participation in pools, joint businesses and international operating agencies. Where an enterprise is carried on by partners with joint liability and residents in both Contracting States and management is not solely in one State, profits are apportioned and taxed in the partners' resident States. Container rental and related equipment income is included. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5387