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 that State. 2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. 3. 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 or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
Appears in 5 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits derived by of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. 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 or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
Appears in 5 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. 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; and
(c) interest on funds connected with the operations of ships or aircraft in international traffic where such rental activity or such use, maintenance or rentalinterest, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
Appears in 4 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Agreement, Double Taxation Agreement
SHIPPING AND AIR TRANSPORT. 1. Profits derived by 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 profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic, if such profits are incidental to the profits to which the provisions of paragraph 1 apply.
3. Profits of an enterprise of a Contracting State from the use, maintenance or rental of containers (including trailers, barges and related equipment for the transport of containers) used for the transport in international traffic of goods or merchandise shall be taxable only in that State.
4. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. 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 or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Income Tax Agreement, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
SHIPPING AND AIR TRANSPORT. 1. Profits derived by 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 profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic, if such profits are incidental to the profits to which the provisions of paragraph 1 apply.
3. Profits of an enterprise of a Contracting State form the use, maintenance or rental of containers (including trailers, barges and related equipment for the transport of containers) used for the transport in international traffic of goods or merchandise shall be taxable only in that State.
4. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. 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 or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
Appears in 3 contracts
Samples: Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
SHIPPING AND AIR TRANSPORT. 1. Profits derived by 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 of an enterprise from the operation of ships or aircraft in international traffic include:
(a) profits from the rental on a full (time or voyage) basis of ships or aircraft, used in international transport;
(b) profits from the rental on a bareboat basis of ships or aircraft; and
(c) profits from the 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, 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 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. 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 or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
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 derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic carried on by an enterprise of a Contracting State shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this Article, Article the terms "profits from the operation of ships or aircraft in international traffic traffic" shall includeinclude profits from:
(a) profits from the rental of a ship or aircraft on a bareboat basis of ships or aircraft; and
(bare boat charter basis, 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 and 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.
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 derived by of an enterprise resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this Article, :
a) the term "profits" includes those derived directly from the operation of ships or aircraft in international traffic; and
b) the terms "profits from the operation of ships or aircraft in international traffic traffic" shall includeinclude profits from:
(ai) profits from the rental of a ship or aircraft on a bareboat basis of ships or aircraftbare boat charter basis; and
(bii) 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 and 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 derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this ArticleArticle and notwithstanding the provisions of Article 12, 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; 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; goods, 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.
Appears in 1 contract
SHIPPING AND AIR TRANSPORT. 1. Profits derived by an enterprise of a Contracting State Party from the operation of ships or aircraft in international traffic shall be taxable only in that StateParty.
2. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. 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 or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
Appears in 1 contract
Samples: 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 that Contracting State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall 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 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.
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 that Contracting State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall 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.,
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 that Contracting State.
2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
3. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall include:
(a) profits 1. income from the rental on a bareboat basis of ships or aircraft; and
(b) 2. 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.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
