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.
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
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 derived from the participation in a pool, a joint business or an international operating agency.
Appears in 4 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise of a Contracting State from the operation of ships ships, aircraft or aircraft road vehicles 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.
Appears in 4 contracts
Samples: Convention for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Income and Capital Tax Convention
INTERNATIONAL TRAFFIC. 1. Profits derived by of an enterprise which is a resident 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.
Appears in 3 contracts
Samples: Double Taxation Agreement, Income and Property Tax Agreement, Agreement for the Avoidance of Double Taxation
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 the Contracting StateState in which the place of effective management of the enterprise is situated.
(2. ) The provisions of paragraph 1 shall also apply to profits derived from the direct use, the letting or any other way of exploitation of containers and equipment pertaining to them.
(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.
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
INTERNATIONAL TRAFFIC. (1. ) Profits derived by an enterprise a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2) Profits derived by a resident of a Contracting State from the operation of boats engaged in inland waterways transport shall be taxable only in that Contracting State.
2. (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 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
INTERNATIONAL TRAFFIC. 1. Profits derived by of an enterprise of a Contracting State from the operation of ships ships, aircraft, railway or aircraft road vehicle transport in international traffic shall be taxable only in that Contracting State.
2. The provisions provision of paragraph 1 shall also apply to the profits from the participation in a pool, a joint business or an international operating agency.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
INTERNATIONAL TRAFFIC. 1. Profits derived by 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. 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 the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise a resident of a Contracting State from the operation of ships ships, aircraft or aircraft road vehicles 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.
Appears in 2 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise a resident of a Contracting State from the operation of ships ships, aircraft, railway or aircraft road vehicles 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.
Appears in 2 contracts
Samples: Income and Capital Tax Agreement, Agreement for the Avoidance of Double Taxation
INTERNATIONAL TRAFFIC. 1. Profits derived by 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. 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: Double Taxation Agreement, Double Taxation Agreement
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise of a Contracting State from the operation of aircraft, road or railway vehicles in international traffic shall be taxable only in that Contracting State.
2. Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft boats in international traffic may be taxed in the other Contracting State, but the tax imposed in that other State shall be taxable only in that Contracting Statereduced by an amount equal to 50 per cent thereof.
23. The provisions of paragraph paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft or road vehicle 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.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise a resident of a Contracting State from the operation of ships ships, aircraft or aircraft road vehicles 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 the Avoidance of Double Taxation, Income and Capital Tax Agreement
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise of a Contracting State from the operation of ships ships, boats 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.
Appears in 1 contract
Samples: Income and Capital Tax Treaty
INTERNATIONAL TRAFFIC. β
1. Profits derived by of an enterprise of a Contracting State from the operation of ships ships, aircrafts or aircraft road transport vehicles 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.
1. Where:
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise of a Contracting State from the operation of ships aircraft or aircraft road vehicle in international traffic shall be taxable only in the Contracting State in which the place of the effective management of the enterprise is situated.
2. Profits derived by a transportation enterprise which is e resident of a Contracting State from the use, maintenance or rental of containers (including trailers and other equipment for the transport of containers) used for the transport of goods or merchandise in international traffic shall be taxable only in that Contracting State unless the containers are used solely within the other Contracting State.
23. The provisions of paragraph paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise of a Contracting State from the operation of ships ships, boats, aircraft, or aircraft road vehicles, and railway, 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.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise which is a resident 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.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits derived by of an enterprise of a Contracting State from the operation of ships ships, aircraft or aircraft road vehicles 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.
Appears in 1 contract
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. Profits derived by an enterprise of a Contracting State from the operation of railway or road transport vehicles in international traffic shall be taxable only in that State where the place of effective management of the enterprise is situated.
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 1 contract
INTERNATIONAL TRAFFIC. 1. Profits derived by of an enterprise of a Contracting State from the operation of ships or aircraft ships, boat, aircraft, railway and road vehicles in international traffic shall be taxable only in that Contracting State.
2. The provisions of paragraph 1 shall also apply to profits derived from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits derived by of an enterprise of a Contracting State Party from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting StateParty.
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.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise of a Contracting State from the operation of ships ships, aircraft, road or aircraft railway vehicles 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.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits derived by The profits of an enterprise of a Contracting State from the operation of ships ships, aircraft or aircraft road vehicles 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.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits derived by an enterprise of a Contracting State from the operation of ships ships, aircraft or aircraft road vehicles in international traffic shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated.
2. Provisions of paragraph 1 above shall apply also to profits derived by any other air, shipping or road vehicle companies, but only to such part of the profits which corresponds to the share held by either of the Contracting State in the above mentioned companies.
3. The provisions of paragraph 1 preceding paragraphs shall also apply to profits from the participation in a pool, a joint business or are an international operating agency.
Appears in 1 contract
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 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
INTERNATIONAL TRAFFIC. 1. Profits derived from the operation of ships, boats, aircraft or vehicles in international traffic by an enterprise a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated.
2. For the purposes of this Article, income from international traffic includes income derived from any form of lease or use of the means of transport referred to in paragraph 1, including income from the operation or lease of containers and associated equipment.
3. The provisions of paragraph paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
Samples: Income and Capital Tax Agreement
INTERNATIONAL TRAFFIC. 1. Profits derived by The 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. 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 1 contract
INTERNATIONAL TRAFFIC. 1. Profits derived by of an enterprise of a Contracting State from the operation of ships ships, aircrafts or aircraft road transport vehicles 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.
Appears in 1 contract
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.
Appears in 1 contract
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.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits from the operation of aircraft, railway or road transport vehicle derived by a resident of a Contracting State shall be taxable only in that State.
2. Profits derived by an enterprise a resident of a Contracting State from the operation of ships or aircraft leasing of the transport, containers and concerning equipment in international traffic shall be taxable only in that Contracting Statestate.
23. The provisions of paragraph paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
1. Where:
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