SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that 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 80 contracts
Samples: Double Taxation Agreement, Convention for the Elimination of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State Party from the operation of ships or aircraft in international traffic shall be taxable only in that 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 23 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of 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 14 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. (1. ) Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that 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 13 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph Paragraph 1 shall also apply to the share of the profits from the operation of ships or aircraft derived by an enterprise of a Contracting State through participation in a pool, a joint business or an international operating agency.
Appears in 13 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business business, or an international operating agency.
Appears in 11 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
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 11 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph Paragraph 1 shall also apply to the share of the profits from the operation of ships or aircraft derived by a resident of a Contracting State through participation in a pool, a joint business or an international operating agency.
Appears in 10 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. 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 9 contracts
Samples: Double Taxation Agreement, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of 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 9 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a one of the Contracting State States from the operation of ships or aircraft in international traffic may be taxed in the other Contracting State, but only if such profits are derived from that other Contracting State. However, the tax charged in respect of such profits in that other State shall be taxable only in that Statereduced by an amount equal to 50 per cent thereof.
2. The provisions of paragraph 1 shall also apply to profits of shipping or air transport enterprises from the participation in a pool, a joint business or an international operating agency.
Appears in 8 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that 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 8 contracts
Samples: Double Taxation Agreement, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise derived by 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 8 contracts
Samples: Double Taxation Agreement, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits derived from the operation of ships or aircraft in international traffic include profits derived from the rental of ships or aircraft if such ships or aircraft are operated in international traffic or if such rental profits are incidental to other 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.
Appears in 7 contracts
Samples: Agreement for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
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 7 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. (1. ) Profits of 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 7 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic carried on by an enterprise of a Contracting State 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 7 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. (1. ) Profits of an enterprise derived by 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 6 contracts
Samples: Convention on Taxes, Convention With Respect to Taxes on Income and on Capital, Convention With Respect to Taxes on Income and on Capital
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic carried on by an enterprise of a Contracting State shall be taxable only in that 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: Double Taxation Agreement, Convention for the Avoidance of Double Taxation, Income and Capital Tax Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic of from the use or rental of containers which is incidental to such operation shall be taxable only in that 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 5 contracts
Samples: Agreement Between the Republic of Indonesia and the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Republic of Indonesia and the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Republic of Indonesia and the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic including rental of containers and related equipment which is incidental to the operation of ships or aircraft shall be taxable only in that Statethe Contracting State of which the enterprise is a resident.
2. The provisions provision of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 5 contracts
Samples: Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
SHIPPING AND AIR TRANSPORT. 1. Profits Income or profits of an enterprise of a Contracting State one of the States from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to income or profits derived from the participation in a pool, a joint business or an international operating agency.
Appears in 5 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph Paragraph 1 shall also apply to the share of the profits from the operation of ships or aircraft derived by an enterprise of a Contracting State through participation in a pool, a joint business or an international operating agency.
Appears in 5 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that 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 5 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. For the purposes of paragraph 1, profits derived from the operation of ships or aircraft in international traffic include profits derived from the rental on a bare-boat basis of ships or aircraft where such rental is incidental to the operation by the enterprise of ships or aircraft in international 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 5 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of Profit which an enterprise of a Contracting State derives from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 of this Article shall also likewise apply to profits from the participation in a poolrespect of participations in pools, in a joint business or in an international operating agencyoperation agency of any kind by enterprises engaged in the operation of ships or aircraft in international traffic.
Appears in 5 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits derived from the operation of ships or aircraft in international traffic include profits derived from the rental of ships or aircraft if such rental profits are incidental to other profits described in paragraph 1.
3. The provisions of paragraph 1 shall also apply to the share of the profits of an enterprise from the participation in a pool, a joint business or an international operating agency.
Appears in 5 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income and Capital Gains
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic by an enterprise of a Contracting State 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 5 contracts
Samples: Agreement for the Elimination of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State derived from the other Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. Profits of an enterprise of a Contracting State derived from the other Contracting State from the operation of ships in international traffic may be taxed in that other State, but the tax chargeable in that other State on such profits shall be reduced by an amount equal to 50 per cent of such tax.
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 5 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. Profits of an enterprise of a Contracting State from the use or rental of containers (including trailers, barges, and related equipment for the transport of containers) used in international traffic shall be taxable only in that State.
3. The provisions of paragraph paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business business, or an international operating agency.
Appears in 4 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits 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 4 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State of which the enterprise operating the ships or aircraft is a resident.
2. 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 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State derived from the operation of ships or aircraft in international traffic by an enterprise of a Contracting State shall be taxable only in that 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: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. Such profits shall include profits derived by that enterprise from the rental on a bareboat basis of ships and aircraft or from the use, maintenance or rental of containers, provided that such activities are incidental to the operation of ships or aircraft in international traffic by that enterprise.
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: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of 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 derived from the participation in a pool, a joint business or an international operating agency.
Appears in 4 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits Income or profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to income or profits derived from the participation in a pool, a joint business or in an international operating agency.
Appears in 4 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic carried on by an enterprise of a Contracting State 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 4 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 Paragraph
(1) shall also apply to the share of the profits from the operation of ships or aircraft derived by a resident of a Contracting State through participation in a pool, a joint business or an international operating agency.
Appears in 3 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State Party from the operation of ships or aircraft in international traffic shall be taxable only in that StateContracting Party.
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 Relief Agreement, Tax Agreement, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The Notwithstanding the provisions of paragraph 1 of Article 7, profits derived from the operation of ships or aircraft solely between places in a Contracting State may be taxed in that State.
3. The provisions of paragraphs 1 and 2 shall also apply to profits derived by an enterprise of a Contracting State from the its participation in a pool, a joint business or in an international operating agency.
Appears in 3 contracts
Samples: Income Tax Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation by that enterprise of ships or aircraft in international traffic shall be taxable only in that 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: Agreement for Avoidance of Double Taxation of Income, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. For the purposes of paragraph 1, profits derived from the operation of ships or aircraft in international traffic include profits derived from the rental on a bare boat basis of ships or aircraft where such rental is incidental to the operation by the enterprise of ships or aircraft in international 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 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that 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 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of the preceding paragraph 1 shall also apply to profits from the participation in a pool, a joint business 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
SHIPPING AND AIR TRANSPORT. (1. ) Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2. ) The provisions of paragraph 1 (1) shall also apply to profits derived 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, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable taxed only in that State.
2. The provisions of paragraph Paragraph 1 shall also apply to share of the profits from the operation of ships or aircraft derived by a resident of a Contracting State through participation in a pool, a joint business or an international operating agency.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the place of head office or of effective management of the enterprise is situated.
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: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of 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, including a consortium or a similar form of association.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of 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 Paragraph 1 shall also apply to the share of the profits from the operation of ships or aircraft derived by a resident of a Contracting State through participation in a pool, a joint business or an international operating agency.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
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: Convention for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion With Mauritius
SHIPPING AND AIR TRANSPORT. 1. Profits derived from sources within one of an enterprise the Contracting States by a resident of a the other Contracting State from the operation of ships or aircraft in international traffic shall may be taxable only taxed in that Stateboth Contracting States.
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 3 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the enterprise is situated. Those profits shall include profits derived by the enterprise from the use, maintenance or rental of containers used for the transport of goods or merchandise in international traffic where such use, maintenance or rental as the case may be, are incidental to the operation of ships or aircraft in international traffic.
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: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Income and Capital Gains Tax Convention
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State of which the enterprise operating the ships or aircraft is a resident.
2. 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 3 contracts
Samples: Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Seychelles for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Seychelles for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Seychelles for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
SHIPPING AND AIR TRANSPORT. 1. Profits derived from the operation of ships engaged in international traffic shall be taxable only in the Contracting State in which the ships are registered.
2. 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 State.
23. The provisions of paragraph paragraphs 1 and 2 of this Article 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 Elimination of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation in international traffic of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions provision 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
SHIPPING AND AIR TRANSPORT. 1. 1 - 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. 2 - 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, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business business, or an international operating agency.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Income Tax Convention
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits derived from the operation of ships or aircraft in international traffic include profits derived from the rental of ships or aircraft if such ships or aircraft are operated in international traffic or if such rental profits are incidental to the operation of ships or aircraft in international 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 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply as well to profits the benefits originating from the participation in a "pool", a consortium or joint business venture or in an international operating agencyorganization or agency engaged in international traffic, but only with regards to the share of the benefits attributable to each participant proportionally to its participation in the joint enterprise.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. 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 of this Article shall also apply to profits derived from the participation in a pool, a joint business or in an international operating agency.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income Tax Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise derived by a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that 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
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation or rental of ships or aircraft in international traffic and the rental of containers and related equipment which is incidental to the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits income 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
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State where the head office of the enterprise is situated.
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, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. (1. ) Profits of derived by an enterprise 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 State.
(2. ) 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 Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the place of effective management is situated.
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, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that StateContracting 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, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State of which the enterprise operating the ships or aircraft is a resident.
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, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation in international traffic of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits derived from the participation in a pool, a joint business 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
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State of which the enterprise is a resident.
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 Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the place of head office or the place of effective management is situated.
2. The Notwithstanding the provisions of paragraph 1 and Article 7, profits derived from the operation of ships or aircraft used principally to transport passengers or goods exclusively between places in a Contracting State may be taxed in that Contracting State.
3. The provisions 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, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft aircrafts in international traffic shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
2. The provisions of preceding paragraph 1 shall also apply to profits from the participation in a pool, a joint business 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
SHIPPING AND AIR TRANSPORT. 1. Profits of 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 2 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic or from the use or rental of containers which is incidental to such operation shall be taxable only in that 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 Avoidance Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of Income and 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 State.
2. The provisions provision of paragraph 1 shall also apply to the share of income and profits from the operation of ships or aircraft derived by a resident of a Contracting State through 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
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. Notwithstanding the provisions of paragraph 1 and Article 7, profits derived from the operation of ships or aircraft used principally to transport passengers or goods exclusively between places in a Contracting State may be taxed in that Contracting State.
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 and the Prevention of Fiscal Evasion
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic carried on by a resident of a Contracting State 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 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the place of head office of the enterprise is situated.
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, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of 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 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions 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 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State Party from the operation of ships or aircraft in international traffic shall be taxable only in that StateParty.
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 Tax Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft air- craft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or business, an international operating agency, a consortium or a similar form of association, but only to so much of the profits so derived as is attributable to the participant in proportion to its share in the joint operation.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise Income or profits derived by 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. Profits referred to in paragraph 1 shall not include profits from the provision of accommodation or transportation other than from the operation of ships or aircraft in international 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 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph Paragraph 1 shall also apply to the share of the profits from the operation of ships or aircraft derived by an enterprise of a Contracting State through participation in a pool, a joint business or an international operating agency.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits of 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.. Where
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
2. The provisions of paragraph Paragraph 1 shall also apply to the share of the profits from the operation of ships or aircraft derived by an enterprise of a Contracting State through 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
SHIPPING AND AIR TRANSPORT. 1. Profits 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 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
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. Profits referred to in paragraph 1 shall not include profits from the provision of accommodation or transportation other than from the operation of ships or aircraft in international 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
Samples: Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation in international traffic of ships or aircraft in international traffic shall be taxable only in that 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.. Where:
Appears in 1 contract
Samples: Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. [1981.04.22]
1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic carried on by an enterprise of a Contracting State shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits derived from the participation in a pool, a joint business or in an international operating agency.
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Statethe Contracting State in which the enterprise is resident.
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: (a)
Appears in 1 contract
Samples: Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft aircraft, in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits derived from the participation in a pool, a joint business or in an international operating agency.
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business business, or an international operating agencyagency but only to so much of the profits so derived as is attributable to the participant in proportion to its share in the joint operation.
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise that is a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions For the purposes of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.this Article:
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships [a] ship or aircraft in international traffic shall be taxable only in that Contracting State.
2. 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: Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions provision 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
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic carried on by an enterprise of a Contracting Party shall be taxable only in that 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
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic carried on by an enterprise of one of the States shall be taxable only in that 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
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation in international traffic of ships or aircraft in international traffic shall be taxable only in that 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: Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise entreprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that 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
SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of aircraft or ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph Paragraph 1 shall also apply to the share of the profits from the operation of ships or aircraft derived by a resident of a Contracting State through participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
