AIR TRANSPORT. 1. Profits derived by an enterprise of a Contracting State from the operation of aircraft in international traffic be taxable only in the 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 a share of profits from the operation of aircraft in international traffic derived by an enterprise of a Contracting State through participation in a pooled service, in a joint air transport operation or in an international operating agency. 3. For the purposes of paragraph 1, interests on funds directly connected with the operation of aircraft in international traffic shall be regarded as income 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, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
AIR TRANSPORT. 1. Profits derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
2. The provisions of paragraph 1 For the purposes of this Article shall also apply to a share of Article:
(a) profits from the operation of aircraft in international traffic of aircraft include profits derived by an enterprise from the rental on a bareboat basis of a Contracting State through participation aircraft if operated in a pooled service, international traffic if such rental profits are incidental to the profits described in a joint air transport operation or in an international operating agency.
3. For the purposes of paragraph 1, interests ;
(b) interest on funds directly connected with the operation of aircraft in international traffic shall be regarded as income profits derived from the operation of such aircraft, aircraft and the provisions of Article 12 11 shall not apply in relation to such interest.
3. The provisions of paragraph 1 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 and Prevention of Fiscal Evasion, Convention for the Avoidance of Double Taxation
AIR TRANSPORT. 1. Profits derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise (that is, the head office) is situated.
2. The provisions of paragraph 1 of this Article shall also apply to a share of profits from the operation of aircraft in international traffic derived by an enterprise of a Contracting State through participation in a pooled servicepool, in a joint air transport operation business or in an international operating agency.
3. For the purposes of paragraph 1this Article, interests interest on funds directly 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 article 12 shall not apply in relation to such interest.
Appears in 1 contract
Samples: Agreement for the Avoidance of Double Taxation and Prevention of Fiscal Evasion
AIR TRANSPORT. 1. Profits derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise (that is, the head office) is situated.
2. The provisions of paragraph 1 of this Article shall also apply to a share of profits from the operation of aircraft in international traffic derived by an enterprise of a Contracting State through participation in a pooled servicepool, in a joint air transport operation business or in an international operating agency.
3. For the purposes of paragraph 1this Article, interests interest on funds directly 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 article 12 shall not apply in relation to such interest.
Appears in 1 contract
Samples: Double Taxation Agreement
AIR TRANSPORT. 1. Profits derived by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
2. The provisions of paragraph 1 of this Article article shall also apply to a share of the profits from the operation of aircraft in international traffic derived by an enterprise of a Contracting State through participation in a pooled serviceservic e, in a joint air transport operation or in an international operating agency.
3. For the purposes of paragraph 1, interests interest on funds directly connected with the operation of aircraft in international traffic shall be regarded as income from the operation of such aircraft, and the provisions of Article article 12 shall not apply in relation to such interest.
Appears in 1 contract
Samples: Double Taxation Agreement
AIR TRANSPORT. 1. Profits derived dervied by an enterprise of a Contracting State from the operation of aircraft in international traffic shall be taxable only in the 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 a share of profits from the operation of aircraft in international traffic derived by an enterprise of a Contracting State through participation in a pooled service, in a joint air transport operation or in an international operating agency.
3. For the purposes purpose of paragraph 1, interests interest on funds directly connected with the operation of aircraft in international traffic shall be regarded as income from the operation of such aircraft, and the provisions of Article 12 11 shall not apply in relation to such interest.
Appears in 1 contract
Samples: Double Taxation Agreement