SHIPPING TRANSPORT. 1. Profits from the operation of ships 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 or a 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 derived from the participation in a pool, a joint business or in an international operating agency.
SHIPPING TRANSPORT. (1) Income or profits derived from the operation of ships in international traffic by an enterprise of a Contracting Party shall be exempt from income tax, profits tax and all other taxes imposed on income or profits in the area of the other Contracting Party.
(2) The provisions of paragraph (1) of this Article shall also apply to income or profits from the participation in a pool, a joint business or in an international operating agency.
(3) Capital and assets of an enterprise of a Contracting Party relating to the operation of ships in international traffic shall be exempt from all taxes on capital and assets imposed in the area of the other Contracting Party.
(4) Gains from the alienation of ships operated in international traffic and movable property pertaining to the operation of such ships which are received by an enterprise of a Contracting Party shall be exempt from any tax on gains imposed in the area of the other Contracting Party.
(5) For the purposes of this Article, the term "income or profits derived from the operation of ships in international traffic" includes revenues and gross receipts from the operation of ships for the transport of persons, livestock, goods, mail or merchandise including the lease of ships operated in international traffic on a full (time or voyage) or bareboat basis.
SHIPPING TRANSPORT. (1) Profits of an enterprise of a Contracting Party from the operation of ships in international traffic shall be taxable only in the area of that Contracting Party.
(2) Capital represented by ships operated by an enterprise of a Contracting Party in international traffic and by movable property pertaining to the operation of such ships shall be taxable only in the area of that Contracting Party.
(3) Gains from the alienation of ships operated by an enterprise of a Contracting Party in international traffic and from movable property pertaining to the operation of such ships shall be taxable only in the area of that Contracting Party.
(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.
(5) For the purposes of this Article, the term “profits of an enterprise of a Contracting Party from the operation of ships in international traffic” includes:
a) revenues and gross receipts from the operation of ships for the transport of persons, livestock, goods, mail or merchandise;
b) profits from the lease of ships on charter fully equipped, manned and supplied or on a bare-boat basis;
c) profits from the use or rental of containers (including trailers and ancillary equipment used for transporting the containers);
d) interest on funds directly connected with that operation.
SHIPPING TRANSPORT. (1) Profits of an enterprise of a Contracting Party from the operation of ships in international traffic shall be taxable only in the area of that Party.
(2) For the purposes of this Article, profits from the operation of ships in international traffic include:
(a) revenues and gross receipts from the operation of ships for the transport of persons, livestock, goods, mail or merchandise;
(i) profits from the rental on a full (time or voyage) or bareboat basis of ships; and
(ii) 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 in international traffic; and
(c) interest on funds directly connected with that operation.
(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.
(4) Gains derived by an enterprise of a Contracting Party from the alienation of ships operated in international traffic by that enterprise, or movable property pertaining to the operation of such ships, shall be taxable only in the area of that Party.
(5) Capital of an enterprise of a Contracting Party represented by ships operated by that enterprise in international traffic, or by movable property pertaining to the operation of such ships, shall be taxable only in the area of that Party.
SHIPPING TRANSPORT. 1. Profits derived by an enterprise of a Contracting Party from the operation of ships in international traffic shall be taxable only in that Contracting Party.
2. Profits from the operation of ships in international traffic include:
(a) profits derived from the rental of ships on a full (time or voyage) basis, or on a bareboat basis, provided that in the case of a bareboat rental, the rental is incidental to the operation of ships in international traffic;
(b) profits derived from the use, maintenance or rental of containers (including trailers, barges and related equipment for the transport of containers) used for the transport of goods or mer- chandise in international traffic if such use, maintenance or rental is incidental to the operation of ships in international traffic;
(c) profits from the sale of tickets or similar documents and the provision of services connected with such operation where such provision of services is incidental to the operation of ships in international traffic, either for the enterprise itself or for another enterprise;
(d) interest on funds directly connected with the operation of ships in international traffic.
3. The provisions of paragraphs l and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
4. Gains derived by an enterprise of a Contracting Party from the alienation of ships operated in international traffic or of movable property (including containers and trailers, barges and related equipment for the transport of containers) pertaining to the operation of such ships shall be taxable only in that Contracting Party.
SHIPPING TRANSPORT. The purchase price of the kitten does not include any shipping or transportation. The Buyer may pick up the kitten in Houston, MO or arrange for Seller to deliver the kitten to an agreed upon location. These costs are in addition to the purchase price stated in paragraph 1. The Seller may agree to meet the Buyer at a location other than Houston, MO to deliver the kitten, however, there will be additional transportation costs for this service. The amount of the cost will depend on the meeting location and will be added as an addendum to this agreement.
SHIPPING TRANSPORT. 1. Profits derived by an enterprise of a Contracting State from the operation of ships in international traffic shall be taxable only in that State.
2. Notwithstanding the provisions of paragraph (1) of this article, profits derived from the operation of ships in international traffic may be taxed in the Contracting State in which such operation is carried on; but the tax so charged shall not exceed 50 per cent of the tax otherwise imposed by the internal law of that State.
3. The provisions of paragraphs (1) and (2) of this article shall also apply to profits derived from the participation in a pool, a joint business or an international operating agency.
1. Protocol signed on 19-7-1985 and ratified on 1-8-1986 forms an integral part of the Convention. It states that for the purposes of articles 8 and 9 of the Convention, it is understood that :
(i) interest on funds connected with the operation of aircraft and ships in international traffic shall also be regarded as profits from the operation of such aircraft and ships; and
(ii) in respect of the operation of aircraft and ships in international traffic carried on by an enterprise of a Contracting State, that enterprise, if an enterprise of India, shall also be exempt from the value added tax in Korea and, if an enterprise of Korea, shall also be exempt from any tax similar to the value added tax in Korea, which may hereafter be imposed in India. Again, in respect of article 9 it is understood that : The provisions of its paragraphs (1) and (2) shall apply in respect of shipping transport carried on or after the taxation year in which an agreement related to shipping transport between the Contracting States or their authorised nominees is concluded and becomes effective. It is further understood that until an agreement related to shipping transport between the Contracting States or their authorised nominees enters into force, paragraph (2) shall read as follows: "profits derived from the operation of ships in international traffic may be taxed in the Contracting State in which such operation is carried on; but the tax so charged shall not exceed 90 per cent of the tax otherwise imposed by the internal law of that State."
SHIPPING TRANSPORT. 1. Profits derived by an enterprise of a Contracting State from the operation of ships in international traffic shall be taxable only in that State.
2. Notwithstanding the provisions of paragraph 1 of this Article, profits derived from the operation of ships in international traffic may be taxed in the Contracting State in which such operation is carried on; but the tax so charged shall not exceed 50 per cent, of the tax otherwise imposed by the internal law of that state.
3. The provisions of paragraphs 1 and 2 of this Article shall also apply to profit derived from the participation in a pool, a joint business or an international operating agency.
