INTERNATIONAL TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships, aircraft or rail or road transport vehicles in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits from the operation of ships, aircraft or rail or road transport vehicles in international traffic shall include: (a) profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic, (b) profits derived from the rental of rail or road transport vehicles, (c) profits derived from the use or rental of containers, 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: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation
INTERNATIONAL TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships, aircraft or rail road or road transport railway vehicles in international traffic shall be taxable only in that State.
2. For the purposes The provisions of this Article, profits from the operation of ships, aircraft or rail or road transport vehicles in international traffic paragraph 1 shall includealso apply to:
(a) occasional profits derived from the rental on a bare boat bareboat basis of ships or aircraft used in international traffic,;
(b) profits derived from the rental of rail or road transport vehicles,
(c) profits derived from the use use, maintenance or rental of containers (including trailers and related equipment for the transport of containers,), if such profits are supplementary or incidental with respect to profits which are covered by paragraph 1.
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.
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Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
INTERNATIONAL TRANSPORT. 1. § 1 Profits of derived by an enterprise of a Contracting State from the operation of ships, aircraft or rail road or road transport railway vehicles in international traffic shall be taxable only in that State.
2. For the purposes § 2 The provisions of this Article, profits from the operation of ships, aircraft or rail or road transport vehicles in international traffic paragraph 1 shall include:
(also apply to: a) occasional profits derived from the rental on a bare boat bareboat basis of ships or aircraft used in international ininternational traffic,
(; b) profits derived from the rental of rail or road transport vehicles,
(c) profits derived from the use use, maintenance or rental of containers (including trailers andrelated equipment for the transport of containers,), if such profits are supplementary or incidental with respect to profits which are covered by paragraph 1.
3. § 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.
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INTERNATIONAL TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships, aircraft or rail road or road transport railway vehicles in international traffic shall be taxable only in that State.
2. For the purposes The provisions of this Article, profits from the operation of ships, aircraft or rail or road transport vehicles in international traffic paragraph 1 shall includealso apply to:
(a) occasional profits derived from the rental on a bare boat bareboat basis of ships or aircraft used in international traffic,;
(b) profits derived from the rental of rail or road transport vehicles,
(c) profits derived from the use use, maintenance or rental of containers (including trailers and related equipment for the transport of containers,), if such profits are supplementary or incidental with respect to profits which are covered by paragraph 1.
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.
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INTERNATIONAL TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships, aircraft or rail aircraft, railway or road transport vehicles in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits from the operation of ships, aircraft or rail or road transport vehicles in international traffic shall include:
(a) profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic,
(b) profits derived from the rental of rail or road transport vehicles,
(c) profits derived from the use or rental of containers,
3. The provisions of paragraph 1 shall also apply to:
(a) incidental profits derived from the rental on a bareboat basis of ships or aircraft operated in international traffic;
(b) profits from the use, maintenance or rental of containers (including trailers and other equipment for the transport of containers), where such profits are supplementary or incidental in respect to the profits to which the paragraph 1 shall apply. The provisions of paragraph 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 TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships, aircraft or rail road or road transport railway vehicles in international traffic shall be taxable only in that State.
2. For the purposes The provisions of this Article, profits from the operation of ships, aircraft or rail or road transport vehicles in international traffic paragraph 1 shall includealso apply to:
(a) occasional profits derived from the rental on a bare boat bareboat basis of ships or aircraft used in international traffic,;
(b) profits derived from the rental of rail or road transport vehicles,
(c) profits derived from the use use, maintenance or rental of containers (including trailers and related equipment for the transport of containers,), if such profits are supplementary or incidental with respect to profits which are covered by paragraph 1.
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.
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INTERNATIONAL TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships, ships or aircraft or rail or road transport vehicles in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits from the operation that are derived by an enterprise of ships, a Contracting State that operates ships or aircraft or rail or road transport vehicles in international traffic shall includeinclude profits derived by that enterprise:
(a) profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic,
(b) profits derived from the rental of rail or road transport vehicles,
(c) profits derived from the use or rental of containers,containers or other related equipment, but only to the extent that such profits are incidental to the profits to which the provisions of paragraph 1 apply.
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
INTERNATIONAL TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships, ships or aircraft or rail or road transport vehicles in international traffic shall be taxable only in that State.
2. For the purposes The provisions of this Article, profits from the operation of ships, aircraft or rail or road transport vehicles in international traffic paragraph 1 shall includealso apply to:
(a) incidental profits derived from the rental (including on a bare boat basis bareboat basic) of ships or aircraft used operated in international traffic,;
(b) profits derived from the rental of rail or road transport vehicles,
(c) profits derived from the use use, maintenance or rental of containers (including trailers and other equipment for the transport of containers,), where such profits are supplementary or incidental in respect to the profits to which the paragraph 1 shall apply.
3. The provisions of paragraph 1 and 2 shall also apply to profits from the participation in a poolpool (in a common fund), a joint business or an international operating agency.
Appears in 1 contract
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion
INTERNATIONAL TRANSPORT.
1. Profits of an enterprise of a Contracting State from the operation of ships, ships or aircraft or rail or road transport vehicles in international traffic shall be taxable only in that State.State.
2. For the purposes of this Article, profits from the operation that are derived by an enterprise of ships, a Contracting State that operates ships or aircraft or rail or road transport vehicles in international traffic shall include:include profits derived by that enterprise:
(a) profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic,traffic,
(b) profits derived from the rental of rail or road transport vehicles,
(c) profits derived from the use or rental of containers,containers or other related equipment, but only to the extent that such profits are ancillary to the profits to which the provisions of paragraph 1 apply.
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.agency.
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