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    <title>International Shipping and Air Transport</title>
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    <description>Profits from operation of ships or aircraft in international traffic are generally taxable only in the enterprise&#039;s Contracting State. Alternative A treats both shipping and air transport profits as taxable solely in that State and extends the rule to pools, joint businesses and international operating agencies. Alternative B treats aircraft profits as taxable only in the enterprise&#039;s State but allows the other State to tax allocated shipping profits where its shipping activities are more than casual; such taxed amounts are to be allocated from overall net shipping profits and reduced by a bilaterally negotiated percentage.</description>
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      <description>Profits from operation of ships or aircraft in international traffic are generally taxable only in the enterprise&#039;s Contracting State. Alternative A treats both shipping and air transport profits as taxable solely in that State and extends the rule to pools, joint businesses and international operating agencies. Alternative B treats aircraft profits as taxable only in the enterprise&#039;s State but allows the other State to tax allocated shipping profits where its shipping activities are more than casual; such taxed amounts are to be allocated from overall net shipping profits and reduced by a bilaterally negotiated percentage.</description>
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