https://www.taxtmi.com/acts?id=20718 Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State where the enterprise's place of effective management is situated, with shipboard management deemed located at the home harbor or the operator's State of residence; source-State taxation of shipping profits is nevertheless permitted subject to a statutory reduction; container rental income is taxable only in the resident State unless used solely in the other State; interest integral to operations is treated as operational profits and Article 11 does not apply; and the rule extends to pools, joint businesses and international operating agencies. en-us Mon, 28 Mar 2016 14:21:54 +0530 Thu, 28 Nov 2024 16:29:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=20718 Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State where the enterprise's place of effective management is situated, with shipboard management deemed located at the home harbor or the operator's State of residence; source-State taxation of shipping profits is nevertheless permitted subject to a statutory reduction; container rental income is taxable only in the resident State unless used solely in the other State; interest integral to operations is treated as operational profits and Article 11 does not apply; and the rule extends to pools, joint businesses and international operating agencies. Act-Rules DTAA Mon, 28 Mar 2016 14:21:54 +0530 https://www.taxtmi.com/acts?id=20718