INTERNATIONAL TRANSPORT. 1. Profits from the operation of ships, aircraft or railway 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. For the purposes of this Article, profits derived from the operation in international traffic of ships and aircraft include profits derived from the rental on a bareboat basis of ships and aircraft if operated in international traffic if such rental profits are incidental to the profits described 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.
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Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
INTERNATIONAL TRANSPORT. 1. Profits from the operation of ships, aircraft or railway 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. For If the purposes place of this Articleeffective management of a shipping enterprise is aboard a ship, profits derived from then it shall be deemed to be situated in the operation Contracting State in international traffic which the home harbour of ships and aircraft include profits derived from the rental on ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a bareboat basis of ships and aircraft if operated in international traffic if such rental profits are incidental to the profits described in paragraph 1resident.
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
INTERNATIONAL TRANSPORT. 1. Profits from the operation of ships, aircraft or railway road-transport 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. For If the purposes place of this Articleeffective management of a shipping enterprise is aboard a ship, profits derived from then it shall be deemed to be situated in the operation Contracting State in international traffic which the home harbour of ships and aircraft include profits derived from the rental on ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a bareboat basis of ships and aircraft if operated in international traffic if such rental profits are incidental to the profits described in paragraph 1resident.
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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INTERNATIONAL TRANSPORT. (1. ) Profits from the operation of ships, ships or aircraft or railway 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. For ) If the purposes place of this Articleeffective management of a shipping enterprise is aboard a ship, profits derived from then it shall be deemed to be situated in the operation Contracting State in international traffic which the home harbour of ships and aircraft include profits derived from the rental on ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a bareboat basis of ships and aircraft if operated in international traffic if such rental profits are incidental to the profits described in paragraph 1resident.
(3. ) The provisions of paragraph 1 shall also apply to profits from the participation in a pool, or a joint business or an international operating agency.
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INTERNATIONAL TRANSPORT. 1. Profits derived from the operation of ships, aircraft or railway vehicles in international traffic shall be taxable only in the Contracting State in which the place of effective management registration (incorporation) of the enterprise is situated.
2. For the purposes Profits derived by an enterprise of this Article, profits derived a Contracting State from the operation in international traffic of ships and aircraft include profits derived from ships, rail or road vehicles, or by boats, may be taxed in the rental on a bareboat basis of ships and aircraft if operated other Contracting State, but the tax imposed in international traffic if such rental profits are incidental that other Contracting State shall be reduced by an amount equal to the profits described in paragraph 150 per cent thereof.
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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