AIR TRANSPORT. 1. Income derived by an enterprise of a Contracting State from the operation of aircraft shall be taxable only in that Contracting State unless the aircraft is operated wholly or mainly between places within the other Contracting State. 2. The provisions of paragraph 1 shall likewise apply in respect of income derived from participation in pools of any kind by enterprises engaged in air transport.
Appears in 4 contracts
Samples: Income Tax Agreement, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
AIR TRANSPORT. 1. Income derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that Contracting State unless the aircraft is operated wholly or mainly between places within the other Contracting State.
2. The provisions of paragraph 1 shall likewise apply in respect of income derived from participation in pools of any kind by enterprises engaged in air transport.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
AIR TRANSPORT. 1. Income derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that the Contracting State unless in which the aircraft place of effective management is operated wholly or mainly between places within the other Contracting Statesituated.
2. The provisions of paragraph 1 shall likewise apply in respect repect of income profits derived from participation in pools of any kind by enterprises engaged in air transport.. Where
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
AIR TRANSPORT. 1. Income derived by an enterprise of a Contracting State from the operation of aircraft in international traffic by an enterprise of one of the Contracting States shall not be taxable only taxed in that Contracting State unless the aircraft is operated wholly or mainly between places within the other Contracting State.
2. The provisions of paragraph 1 shall likewise also apply in respect of income derived to profits from the participation in pools a pool, a joint business or an international operating agency.
3. For the purposes of any kind by enterprises engaged this Article:
a. interest of funds connected with the operation of aircraft in air transport.international traffic shall be regarded as income from the operation of such aircraft; and
Appears in 1 contract
Samples: Double Taxation Agreement
AIR TRANSPORT. (1. ) Income derived from the operation by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in that the Contracting State unless in which the aircraft place of effective management of the enterprise is operated wholly or mainly between places within the other Contracting Statesituated.
(2. ) The provisions of paragraph 1 this Article shall likewise apply to the share in respect of income derived from participation in aircraft pools of any kind by enterprises such an enterprise engaged in air transport.
Appears in 1 contract
Samples: Double Taxation Convention
AIR TRANSPORT. 1. Income derived by an enterprise of a Contracting State from the operation of aircraft by an enterprise of one of the Contracting States shall not be taxable only taxed in that the other Contracting State unless the aircraft is operated wholly or mainly between places within the that other Contracting State.
2. The provisions of paragraph Paragraph 1 shall likewise apply in respect of income derived from participation participations in pools of any kind by enterprises engaged in air transport.
3. For the purpose of paragraph 1, interest on funds directly connected with the operation of aircraft in international traffic shall be regarded as income from the operation of such aircraft.
Appears in 1 contract
Samples: Double Taxation Agreement