AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that State. 2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 6 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 4 contracts
Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that Contracting State.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this Article, interest on funds directly connected with the operation of aircraft in international traffic shall be regarded as income or profits derived from the operation of such aircraft, and the provisions of Article 12 shall not apply in relation to such interest.
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency, but only so much of it which is attributable to its participation in joint operation.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
AIR TRANSPORT. 1 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that Contracting State.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 2 contracts
Samples: Agreement for Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this article, interest on funds connected with the operation of aircraft in international traffic shall be regarded as profits derived from the operation of such aircraft, and the provisions of article 12 shall not apply in relation to such interest.
Appears in 2 contracts
Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that Contracting State.
2. The provisions of paragraph 1 (1) shall likewise apply in respect of this Article shall also apply to profits income derived from the participation in a pool, a joint business or an international operating agencypools of any kind by enterprises engaged in air transport.
Appears in 2 contracts
Samples: Double Taxation Agreement, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
2. The provisions of paragraph 1 of this Article shall also apply to the profits from the participation in a βpoolβ, a joint business business, or an international operating agency.
Appears in 1 contract
Samples: Income and Capital Tax Convention
AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this Article, interest on funds connected with the operation of aircraft in international traffic shall be regarded as profits derived from the operation of such aircraft, and the provisions of article 12 shall not apply in relation to such interest.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this Article, interest on funds connected with the operation of aircraft in international traffic shall be regarded as income/profits derived from the operation of such aircraft, and the provisions of Article 11 shall not apply in relation to such interest.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion With Nepal
AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
Samples: Double Taxation Agreement
AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 of this Article (1) shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation of Income
AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this article, interest on funds connected with the operation of aircraft in international traffic shall be regarded as profits derived from the operation of such aircraft and the provisions of article 12 shall not apply in relation to such interest.
Appears in 1 contract
Samples: Double Taxation Agreement
AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this Article, interest on funds connected with the operation of aircraft in international traffic shall be regarded as income/profits derived from the operation of such aircraft, and the provisions of Article 11 shall not apply in relation to such interest.
Appears in 1 contract
Samples: Double Taxation Agreement
AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that Contracting State.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purpose of this article, interest on funds connected with the operation of aircraft in international traffic shall be regarded as profits derived from the operation of such aircraft, and the provisions of article 12 shall not apply in relation to such interest.
Appears in 1 contract
AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph paragraphs 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
