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 from the operation of ships or aircraft in international traffic include: a) profits from the rental on a bareboat basis of ships or aircraft; and b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is 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 11 contracts
Samples: Double Taxation Agreement, Double Taxation Convention, 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. ) For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
a) profits from the rental on a bareboat basis of ships or aircraft; and
b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is 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 7 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Agreement, 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 State.
2. For the purposes purpose of this Article, profits from the operation of ships or aircraft in international traffic include:
a) profits from the rental on a bareboat bare boat basis of ships or aircraft; and
b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; , where such rental or such use, maintenance or rental, as the case may be, is 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 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 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 from the operation of ships or aircraft in international traffic include:
(a) profits from the rental on a bareboat basis of ships or aircraft; and
(b) profits from the use, maintenance use or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance use or rental, as the case may be, is incidental to the operation of such ships or aircraft in international traffic.
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, 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 3 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 derived by an enterprise of a Contracting State territory from the operation of ships or aircraft in international traffic shall be taxable only in that Stateterritory.
2. For the purposes purpose of this Article, profits from the operation of ships or aircraft in international traffic include:
a) profits from the rental on a full (time or voyage) basis or a bareboat basis of ships or aircraft; and
b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is 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, 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 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, 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 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 from the operation of ships or aircraft in international traffic shall include:
(a) profits from the rental on a bareboat basis of ships or aircraft; and
(b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) ), used for the transport of goods or merchandise; where such rental rental, use or such use, maintenance or rentalmaintenance, as the case may be, is 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 3 contracts
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation, 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. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
a) profits from the rental on a bareboat basis of ships or aircraft; and
b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is 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, 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 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. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
a) profits from the rental on a bareboat basis of ships or aircraft; and
b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
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: Tax 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 Contracting State.
2. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
a) profits from the rental on a bareboat bare boat basis of ships or aircraft; and
b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; , where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
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 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. For the purposes of this Articlearticle, profits from the operation of ships or aircraft in international traffic shall include:
(a) profits from the rental bareboat rental, on a bareboat random basis of ships or aircraft; andaircraft in international traffic;
(b) profits from the use, maintenance or rental of containers (in international traffic ( including trailers and related equipment for the transport transportation of containers) used for the transport of goods or merchandise; where such rental kind of activities are supplementary or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
3. The provisions of paragraph preceding 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 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 from the operation of ships or aircraft in international traffic shall include:
(a) profits from the rental on a bareboat bare boat basis of ships or aircraft; and
(b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; , where such rental or such use, maintenance or rental, as the case may be, is 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, but only to so much of the profits so derived as is attributable to the participation held in the joint operation.
Appears in 2 contracts
Samples: Double Taxation Agreement, 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 from the operation of ships or aircraft in international traffic include:
(a) profits from the rental on a bareboat basis of ships or aircraft; and
(b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
(3. ) The provisions of paragraph 1 (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: 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 from the operation of ships or aircraft in international traffic include:
(a) profits from the rental on a bareboat basis of ships or aircraft; and
(b) profits from the use, maintenance use or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance use or rental, as the case may be, is incidental to the operation of such ships or aircraft in international traffic.
(3. ) The provisions of paragraph 1 (1) of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency, 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 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 from the operation of ships or aircraft in international traffic include:
(a) profits from the rental on a bareboat basis of ships or aircraft; and
(b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
(3. ) The provisions of paragraph 1 (1) of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency, 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: Income and Capital Tax Convention, 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 and aircraft in international traffic shall be taxable only in that State.
2. For the purposes purpose of this Article, profits from the operation of ships or aircraft in international traffic includeinclude :
(a) profits income from the rental on a bareboat basis of ships or aircraft; and
(b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; , where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
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
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. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
a) a. profits from the rental on a bareboat basis of ships or aircraft; and
b) b. profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
3. The provisions of paragraph 1 (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 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, Article profits from the operation of ships or aircraft in international traffic include:
a) profits income from the rental on a bareboat basis of ships or aircraft; and
b) profits from the use, maintenance or rental of containers (including trailers trailers, barges and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
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
Samples: 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 that State.
2. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
a) profits from the rental on a bareboat basis of ships or aircraft; and
b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation by an enterprise of a Contracting State of ships or aircraft in international traffic.
3. 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 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. ) For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
(a) profits from the rental on a bareboat basis of ships or aircraft; and
(b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
(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: 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 that State.
2. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
(a) profits income from the rental on a bareboat basis of ships or aircraft; and
(b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; , where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
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 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, Article profits from the operation of ships or aircraft in international traffic include:
a) profits from the rental on a bareboat basis of ships or aircraft; and;
b) profits from the use, maintenance or rental of containers (containers, including trailers and related equipment for the transport of containers) , used for the transport of goods or merchandise; , where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic.
3. The provisions of paragraph 1 shall also apply to profits from the participation in a the 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 that State.
2. ) For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
a) profits from the rental on a bareboat basis of ships or aircraft; and
b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is 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, 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 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 from the operation of ships or aircraft in international traffic include:
a) a. profits from the rental on a bareboat basis of ships or aircraft; and
b) b. profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
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
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 from the operation of ships or aircraft in international traffic include:
(a) profits from the rental on a bareboat basis of ships or aircraft; and
(b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
3. The provisions of paragraph 1 (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
