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.
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, road or aircraft railway vehicles in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise 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 har- xxxx 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: Double Taxation Agreement, Convention 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 taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise enterprise is situated.
(2. ) If the place of effective management of a shipping enterprise is aboard a shipship or boat, then it shall be deemed to be situated in the Contracting State in which the home har- xxxx harbour of the ship or boat 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 (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 Agreement
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships or aircraft in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of head office (i. e. effective management management) of the en- terprise enterprise is situated.
2. If the place of head office (i. e. effective management 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 harbour of the ship is situated, or, 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: 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 ships, aircraft, railway and road vehicles in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise 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 state in which the home har- xxxx 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 from the operation of ships ships, boats, aircraft or aircraft road transport vehicles in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise enterprise is situated.
2. If the place of effective management of a shipping enterprise is aboard a shipship or boat, then it shall be deemed to be situated in the Contracting State in which the home har- xxxx harbor of the ship or boat is situated, or, if there is no such home harbourharbor, 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 of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise is situatedthat State.
2. If For the place purposes of effective management this Article, the term “operation of ships or aircraft in international traffic” by an enterprise of a shipping Contracting State, includes:
(1) the charter or rental on a bare boat basis of ships or aircraft,
(2) the rental of containers (including trailers and related equipment for the transport of containers) by that enterprise if that charter or rental is aboard a ship, then it shall be deemed incidental to be situated the operation by that enterprise of ships or aircraft 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 residentinternational 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.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships or aircraft ships, boats, aircraft, railway and road vehicles in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise enterprise is situated.
2. If the place of effective management of a shipping enterprise is aboard a ship, or boat then it shall be deemed to be situated in the Contracting State state in which the home har- xxxx harbor of the ship or boat is situated, or, if there is no such home harbourharbor, 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 derived 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 ships, aircraft, railway or aircraft road vehicles in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise 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 har- xxxx harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of or 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 ships, aircraft, railway or aircraft road vehicles in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise 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 har- xxxx 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
Samples: Double Taxation Agreement
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships ships, aircraft or aircraft road vehicles in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise enterprise is situated.
2. If the place of effective management of a shipping enterprise is aboard a shipship or boat, then it shall be deemed to be situated in the Contracting State in which the home har- xxxx harbour of the ship or boat 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 (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: Double Tax Treaty
INTERNATIONAL TRAFFIC. 1. Profits from the operation of ships ships, boats, aircraft or aircraft road-transport vehicles in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise enterprise is situated.
2. If the place of effective management of a shipping enterprise is aboard a shipship or boat, then it shall be deemed to be situated in the Contracting State in which the home har- xxxx harbour of the ship or boat 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 ships, boats, aircraft, road or aircraft railway vehicles in international traffic shall be taxa- ble taxable only in the Contracting State in which the place of effective management of the en- terprise enterprise is situated.
2. If the place of effective management of a shipping enterprise is aboard a shipship or boat, then it shall be deemed to be situated in the Contracting State in which the home har- xxxx harbour of the ship or boat 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
Samples: Income and Capital Tax Agreement