SHIPPING AND AIR TRANSPORT. 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 90 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 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 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 24 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. (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 19 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Elimination of Double Taxation
SHIPPING AND AIR TRANSPORT. 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 and control of the enterprise is situated.
2. If the place of effective management and control 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 8 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 from the operation of ships or aircraft aircrafts 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 7 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 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 derived from the participation in a pool, a joint business or in an international operating agency.
Appears in 6 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 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 shipship or boat, then it shall be deemed to be situated in the Contracting State in which the home 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 6 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Income and Capital Tax Convention
SHIPPING AND AIR TRANSPORT. (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 of this Article 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, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits derived by 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 Notwithstanding the place provisions of effective management Article 7 or of paragraph 1 of this Article, profits derived from the operation of ships or aircraft used principally to transport goods or passengers exclusively between places in a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State may be taxed 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 residentthat State.
3. The provisions of paragraph 1 this Article shall also apply to profits referred to in this Article 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 6 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 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 or head office of the enterprise is situated.
2. If the place of effective management or 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 6 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, 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 shall be taxable only in that State.
(2) For the purposes of this Article, profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall include inter alia profits derived from the use or rental of containers, if such profits are incidental to the profits to 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 apply.
(3) The provisions of 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: 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 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, 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 derived from the participation in a pool, a joint business or in an international operating agency.
Appears in 5 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income Tax Convention, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 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 head office (i. e. effective management management) 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 5 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, 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 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 5 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 derived 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 derived 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 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, the expression “operation of ships or aircraft” by an enterprise, includes:
(a) the charter or rental on a shipping enterprise is aboard a ship, then it shall be deemed to be situated in bareboat basis of ships and aircraft,
(b) the Contracting State in which the home harbour rental of the ship is situated, orcontainers and related equipment, if there that charter or rental is no such home harbour, incidental to the operation by the enterprise of ships or aircraft 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 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 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, 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 5 contracts
Samples: Double Taxation Agreement, Income Tax Agreement, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 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 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 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Income and Capital Tax Convention
SHIPPING AND AIR TRANSPORT. 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 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 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 from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of head office or effective management of the enterprise is situated.
2. If the place of head office or 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
SHIPPING AND AIR TRANSPORT. 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 Profits of effective management an enterprise of a shipping enterprise is aboard a shipContracting State from the operation of ships in international traffic may be taxed in that State. However, then it such profits derived from sources within the other Contracting State may also be taxed in that other State provided that the tax so charged in that other Contracting State 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 residentreduced by 50%.
3. The provisions of paragraph 1 foregoing paragraphs 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: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 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 derived from the participation in a pool, a joint business or an international operating agency.
Appears in 4 contracts
Samples: Income and Capital Tax Convention, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 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 shipship or boat, 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 in 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 3 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft in international traffic shall be taxable tax- able 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 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 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 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 3 contracts
Samples: Income Tax Convention, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 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 head office or effective management of the enterprise is situated.
2. If the place of head office or 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, 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 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 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 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 Agreement, Income and Capital Tax Agreement, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 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 3 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 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 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.
4. Notwithstanding paragraph 1 of this Article, profits derived by a resident of a Contracting State from the operation of ships used for the transport of hydrocarbons in the other Contracting State may be taxed in that other State.
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 or rental 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 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
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 the that Contracting State in which the place of effective management of the enterprise is situatedState.
2. If the place of head office (place of 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 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: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft aircrafts 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.
1. Where:
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 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 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
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 the Contracting State in which the place of effective management of the enterprise is situatedthat State.
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
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships ship 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, situated or if there is no such home harbour, 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 derived from the participation in a pool, a joint business or in an international operating agency.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 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, 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 derived from the participation in a pool, a joint business or in an international operating agency.
4. The provisions of paragraph 1 above shall also apply to Gulf Air, but only to such part of the profits which corresponds to the share held by the State of Qatar in the above company.
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 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 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 Contracing 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
SHIPPING AND AIR TRANSPORT. 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, or if there is no such home harbour, in the Contracting State of which the operator of the ship is a residentreasident.
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
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or and aircraft in international traffic shall be taxable only in the Contracting State in of which the place of effective management of enterprise operating the enterprise ships or aircraft is situateda resident.
2. If Notwithstanding the place provisions of effective management paragraph 1, the profits of an enterprise of a shipping enterprise is aboard a ship, then it contracting state from operation of ships in international traffic from sources within the other contracting state may be taxed in the other state in accordance with domestic laws provided that the tax so charged shall be deemed reduced by an amount equal 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 residentfifty percent 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.
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 from the operation of ships or aircraft aircrafts 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 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: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits 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 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 shipship or boat, 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 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. (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, 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 (1) 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 and the Prevention of Fiscal Evasion, Agreement for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft aircrafts 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 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 preceding 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, Income 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 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, the expression “operation of ships or aircraft” by an enterprise, also includes:
(i) the charter or rental on a shipping enterprise is aboard a ship, then it shall be deemed to be situated in bareboat basis of ships and aircraft;
(ii) the Contracting State in which the home harbour rental of the ship is situated, orcontainers and related equipment, if there that charter or rental is no such home harbour, incidental to the operation by the enterprise of ships or aircraft 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 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 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 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Income and Inheritance Tax Convention
SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise 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 2 contracts
Samples: Double Taxation Agreement, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State of which the enterprise is a resident and in which the place of effective management of the enterprise is situated.
2. If For the place purposes of effective management this Article, profits derived from the operation in international traffic of ships and aircraft include profits derived from the rental on a shipping enterprise is aboard a ship, then it shall be deemed bareboat basis of ships and aircraft if operated in international traffic if such rental profits are incidental to be situated the profits described 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 residentparagraph 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 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 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, or if there is no such home harbour, 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, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 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 of this Article 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 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
SHIPPING AND AIR TRANSPORT. 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, 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
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft in international traffic by an enterprise of a Contracting State shall be taxable only in the that Contracting State in which the place of effective management of the enterprise is situatedState.
2. If the place of head office or 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 operafor 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
SHIPPING AND AIR TRANSPORT. 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 or boat 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 derived from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
Samples: Tax Treaty
SHIPPING AND AIR TRANSPORT. 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 Notwithstanding the place provisions of effective management paragraph 1 and Article VII, profits derived from the operation of ships or aircraft used principally to transport passengers or goods exclusively between places in a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State may be taxed 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 residentthat State.
3. The provisions of paragraph paragraphs 1 and 2 shall also apply to profits referred to in those paragraphs 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 1 contract
Samples: Income and Capital Tax Convention
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft aircrafts in international traffic shall be taxable only in the Contracting State Party 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 Party in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State Party 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.
1. Where
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 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 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 1 contract
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft aircrafts in international traffic shall be taxable only in the Contracting State Party 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 Party in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State Party 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.
1. Where:
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 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 derived from the participation in a pool, a joint business or an international operating agency.
4. Profits from the use or rental of containers (including trailers and related equipment for the transport of containers) used in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 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, 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 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 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 in 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
SHIPPING AND AIR TRANSPORT. 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 xxxxxxxxxx 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 1 contract
SHIPPING AND AIR TRANSPORT. 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 1 contract
Samples: Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 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, 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 (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 shall be taxable only in the that Contracting State in which the place of effective management of the enterprise is situatedState.
2. If the place of head office(place of 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 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
SHIPPING AND AIR TRANSPORT. 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 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 derived by 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 derived by an enterprise of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State from the operation of ships or aircraft in international traffic shall include inter alia profits derived from the use or rental of containers, if such profits are incidental to the profits to which the home harbour provisions 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 residentparagraph 1 apply.
3. 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 1 contract
Samples: Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft in international traffic shall be taxable taxed 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 1 contract
Samples: Income and Capital 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 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 the expression “operation of ships and aircraft“ by an enterprise includes:
a) the charter or rental on a shipping enterprise is aboard a ship, then it shall be deemed to be situated in bareboat basis of ships and aircraft;
b) the Contracting State in which the home harbour rental of the ship is situated, orcontainers and related equipment, if there that charter or rental is no such home harbour, incidental to the operation by the enterprise of ships or aircraft 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
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 the Contracting State in which the place of effective management of the enterprise is situatedthat State.
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 1 contract
SHIPPING AND AIR TRANSPORT. 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 venture or an international operating business agency.
Appears in 1 contract
Samples: Income and Capital Tax Convention
SHIPPING AND AIR TRANSPORT. (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 this Article shall also apply to profits derived from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
Samples: Double Taxation Convention
SHIPPING AND AIR TRANSPORT. 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 Profits of effective management an enterprise of a shipping enterprise is aboard a shipContracting State from the operation of ships in international traffic may be taxed in that State. However, then it such profits derived from sources within the other Contracting State may also be taxed in that other State provided that the tax so charged in that other Contracting State 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 residentreduced by 50%.
3. The provisions of paragraph 1 the foregoing paragraphs of this Article 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
SHIPPING AND AIR TRANSPORT. 1. Profits derived from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State Party 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 Party in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State Party 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
SHIPPING AND AIR TRANSPORT. 1. Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international 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 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 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 the Contracting State in which the place of effective management of the enterprise is situatedthat State.
2. If For purposes of this Article, profits from the place operation of effective management ships or aircraft include, but are not limited to:
a) the charter or rental on a bareboat basis of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in ships and aircraft;
b) the Contracting State in which the home harbour rental of the ship is situated, orcontainers and related equipment, if there that charter or rental is no such home harbour, incidental to the operation by the enterprise of ships or aircraft 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
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 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 the expression "operation of ships and aircraft" by an enterprise includes:
a) the charter or rental on a shipping enterprise is aboard a ship, then it shall be deemed to be situated in bareboat basis of ships and aircraft;
b) the Contracting State in which the home harbour rental of the ship is situated, orcontainers and related equipment, if there that charter or rental is no such home harbour, incidental to the operation by the enterprise of ships or aircraft in the Contracting State of which the operator of the ship is a residentinternational traffic.
3. The provisions of paragraph 1 this Article 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 from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State Party 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 Party in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State Party 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
SHIPPING AND AIR TRANSPORT. 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 abroad a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, 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 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 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 in which the operator of the ship is a residentdomiciled.
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 Convention
SHIPPING AND AIR TRANSPORT. 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 shipship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbour 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
SHIPPING AND AIR TRANSPORT.
(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 this Article shall also apply to profits derived from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
Samples: Double Taxation Convention
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft aircrafts in international traffic shall be taxable only in the Contracting State Party 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 Party in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State Party 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
SHIPPING AND AIR TRANSPORT. 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.
1. Where:
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 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 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
SHIPPING AND AIR TRANSPORT. 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 derived from the participation in a pool, in a joint business or in an international operating operations agency.
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft aircrafts 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 residentresident .
3. The provisions of preceding 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 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 harbor 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
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft in international traffic by an enterprise of a Contracting State shall be taxable only in the that Contracting State in which the place of effective management of the enterprise is situatedState.
2. If For the place purpose of effective management this Article, profits from the operation of ships or aircraft in international traffic shall include profits from:
(a) the rental of a shipping enterprise is aboard ship or aircraft on a ship, then it shall be deemed bare boat charter basis in international traffic; and
(b) the use or rental of containers where such profits are incidental to be situated in the Contracting State in profits to which the home harbour provisions 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 residentparagraph 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.
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. (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 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: Income and Capital Tax Agreement
SHIPPING AND AIR TRANSPORT. (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 (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
SHIPPING AND AIR TRANSPORT. 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 1 contract
SHIPPING AND AIR TRANSPORT. 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 situated 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 1 contract
Samples: Income Tax Convention
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft aircrafts 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 residentresident .
3. The provisions of preceding 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 derived by 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 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, situated or if there is no such home harbour, 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
SHIPPING AND AIR TRANSPORT. 1. Profits derived by 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 Notwithstanding the place provisions of effective management paragraphs 1, profits from sources within a Contracting State derived by an enterprise of a shipping enterprise is aboard a ship, then it shall the other Contracting State from the operation of ships in international traffic may be deemed to be situated taxed in the Contracting first-mentioned State in which but the home harbour tax so charged shall not exceed 50 per cent of the ship is situated, or, if there is no such home harbour, in tax otherwise imposed by the Contracting State internal law of which the operator of the ship is a residentthat State.
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 1 contract
SHIPPING AND AIR TRANSPORT. 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 derived from the participation in a pool, in a joint business or in an international operating operations agency.
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State Country 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 Country in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State Country 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
SHIPPING AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft in international traffic 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 I 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 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 Contract- ing 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, but only to such part of the profits so derived as relates to the participation held in the joint operation.
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 the Contracting State in which the place of effective management of the enterprise is situatedthat State.
2. If the place of effective management Profits derived by an enterprise of a shipping enterprise is aboard a shipContracting State from the operation of ships in international traffic may be taxed in the other Contracting State, then it but the tax imposed in that other State shall be deemed reduced by an amount equal 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 residentfifty (50) per cent thereof.
3. The provisions of paragraph 1 and 2 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 1 contract
Samples: Double Taxation Avoidance Agreement
