INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships or 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. If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident.
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.
INTERNATIONAL TRAFFIC. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships or aircraft in international traffic shall be taxa- ble only in the Contracting State in which the place of effective management of the en- terprise is situated.
2. If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home har- xxxx of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident.
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.
INTERNATIONAL TRAFFIC. 1. Profits of an enterprise of a Contracting State from the operation of ships, aircraft or road vehicles in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits of an enterprise of a Contracting State from the operation of ships, aircraft or road vehicles in international traffic include:
a) profits from the rental on a bareboat basis of ships, aircraft or road vehicles; and
b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships, aircraft or road vehicles in international traffic.
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.
INTERNATIONAL TRAFFIC. 1. Profits of the enterprise of a Contracting State from the operation of ships, boats, aircraft, railway or road vehicles in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits from the operation of ships, boats, aircraft, railway or road vehicles in international traffic also include profits from the rental on a bareboat basis of ships, boats, aircraft, railway or road vehicles when used in international traffic, where profits from such rental are incidental to the profits referred to in paragraph 1.
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.
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships or 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. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include profits derived from the rental of ships or aircraft on a full (time or voyage) basis or on a bareboat basis, if such rental activities are incidental to the activities described in paragraph 1.
3. Profit of an enterprise of a Contracting State from the use, maintenance or rental of containers (including trailers, barges and related equipment for the transport of containers) that is incidental to profit from the operation of ships or aircraft in international traffic shall be treated for the purposes of paragraph 1 as profit from the operation of ships or aircraft in international traffic.
4. If the place of effective management of a shipping enterprise is aboard a ship then it shall be deemed to be situated in the Contracting state in which the home harbor of the ship is situated, or, if there is no such home harbor, in the Contracting State of which the operator of the ship is a resident.
5. The provisions of paragraph 1 shall apply to profits derived from the participation in a pool, a joint business or an international operating agency.
INTERNATIONAL TRAFFIC. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State.
2. Notwithstanding the provisions of Article 2, an enterprise of a Contracting State shall be exempt in respect of its carrying on the operation of ships or aircraft in international traffic from, in the case of an enterprise of Serbia, the enterprise tax of Japan and, in the case of an enterprise of Japan, any tax similar to the enterprise tax of Japan which is imposed after the date of signature of this Convention in Serbia.
3. The provisions of paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
INTERNATIONAL TRAFFIC. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
a) profits from the rental on a bareboat basis of ships or aircraft; and
b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
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, but only to so much of the profits so derived as is attributable to the participant in proportion to its share in the joint operation.
INTERNATIONAL TRAFFIC. 1. Income or profits 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. Income or profits derived by an enterprise of a Contracting State from the operation of ships in international traffic may be taxed in the other Contracting State, but the tax imposed in that other State shall be reduced by an amount equal to 50% thereof.
3. The provisions of paragraph 1 and 2 shall also apply to income or profits from participation in a pool, a joint business or an international operating agency.
