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.
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Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships or aircraft 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.
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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 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.
Appears in 4 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 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 head office of the enterprise is situated.
2. If the place of effective management head office 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 harbor of the ship is situated, or, if there is no such home harbourharbor, 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.
Appears in 2 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships ships, aircraft or aircraft road vehicles 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.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships ships, aircraft or aircraft road vehicle in international traffic shall be taxable only in the Contracting State in which the place of effective management head office of the enterprise is situated.
2. If the place of effective management head office 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, 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.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
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 head office of the enterprise is situated.
2. If the place of effective management head office 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.
Appears in 1 contract
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 or boat 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.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships or ships, aircraft and road vehicles 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, ship then it shall be deemed to be situated in the Contracting State in which the home harbour harbor of the ship is situated, or, if there is no such home harbourharbor, 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 derived from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
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 the Contracting State in which the place of effective management of the enterprise is situatedthat State.
2. If For the place purposes of effective management this Article, profits from the operation in international traffic of ships or aircraft, referred to in paragraph 1, shall include profits from the leasing of ships or aircraft on a shipping bareboat charter basis where it is an ancillary activity of an enterprise is aboard a ship, then it shall be deemed to be situated engaged in the Contracting State in which the home harbour international operation 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 residentships and aircraft.
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.
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