Ships and Aircraft. 1. Profits from the operation of ships or aircraft devived by a resident of a Contracting State shall be taxable only in that State. 2. Notwithstanding the provisions of paragraph 1, such profits may be taxed in the other Contracting State where they are profits from operations of ships or aircraft confined solely to places in that other State. 3. The provisions of paragraphs 1 and 2 shall apply in relation to the share of the profits from the operation of ships or aircraft derived by a resident of a Contracting State through participation in a pool service, in a joint transport operating organisation or in an international operating agency. 4. For the purposes of this Article, profits derived from the carriage by ships or aircraft of passengers, livestock, mail, goods or merchandise shipped in a Contracting State for discharge at another place in that State shall be treated as profits from operations of ships or aircraft confined solely to places in that State.
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Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
Ships and Aircraft. 1. Profits from the operation of ships or aircraft devived in international traffic derived by a resident of a one of the Contracting State States shall be taxable only in that State.
2. Notwithstanding the provisions of paragraph 1, such profits may be taxed in the other Contracting State where they are profits from operations of ships or aircraft confined solely to places in that other State.
3. The provisions of paragraphs 1 and 2 shall apply in relation to the share of the profits from the operation of ships or aircraft derived by a resident of a one of the Contracting State States through participation in a pool service, in a joint transport operating organisation or in an international operating agency.
4. For the purposes of this Article, profits derived from the carriage by ships or aircraft of passengers, livestock, mail, goods or merchandise shipped in a Contracting State for discharge at another place in that State shall be treated as profits from operations of ships or aircraft confined solely to places in that State.
Appears in 1 contract
Samples: International Tax Agreements
Ships and Aircraft. 1. Profits from the operation of ships or aircraft devived derived by a resident of a one of the Contracting State States shall be taxable only in that State.
2. Notwithstanding the provisions of paragraph 1, such profits may be taxed in the other Contracting State where they are profits from operations of ships or aircraft confined solely to places in that other State.
3. The provisions of paragraphs 1 and 2 shall apply in relation to the share of the profits from the operation of ships or aircraft derived by a resident of a Contracting State through participation in a pool service, in a joint transport operating organisation or in an international operating agency.
4. For the purposes of this Article, profits derived from the carriage by ships or aircraft of passengers, livestock, mail, goods or merchandise shipped in a one of the Contracting State States for discharge at another place in that State shall be treated as profits from operations of ships or aircraft confined solely to places in that State.
Appears in 1 contract
Samples: Double Taxation Agreement
Ships and Aircraft. 1. Profits from the operation of ships or aircraft devived derived by a resident of a one of the Contracting State States shall be taxable only in that State.
2. Notwithstanding the provisions of paragraph 1, such profits may be taxed in the other Contracting State where they are profits from operations of ships or aircraft confined solely to places in that other State.
3. The provisions of paragraphs 1 and 2 shall apply in relation to the share of the profits from the operation of ships or aircraft derived by a resident of a one of the Contracting State States through participation in a pool service, in a joint transport operating organisation organization or in an international operating agency.
4. For the purposes of this Article, profits derived from the carriage by ships or aircraft of passengers, livestock, mail, goods or merchandise shipped in a Contracting State for discharge at another place in that State shall be treated as profits from operations of ships or aircraft confined solely to places in that State.
1. Where:
Appears in 1 contract
Samples: International Tax Agreements
Ships and Aircraft. 1. Profits from the operation of ships or aircraft devived derived by a resident of a one of the Contracting State States shall be taxable only in that State.
2. Notwithstanding the provisions of paragraph 1, such profits may be taxed in the other Contracting State where they are profits from operations of ships or aircraft confined solely to places in that other State.
3. The provisions of paragraphs 1 and 2 shall apply in relation to the share of the profits from the operation of ships or aircraft derived by a resident of a one of the Contracting State States through participation in a pool service, in a joint transport operating organisation organization or in an international operating agency.
4. For the purposes of this Article, profits derived from the carriage by ships or aircraft of passengers, livestock, mail, goods or merchandise shipped in a Contracting State for discharge at another place in that State shall be treated as profits from operations of ships or aircraft confined solely to places in that State.. 1. Where:
Appears in 1 contract
Samples: International Tax Agreements
Ships and Aircraft. 1. Profits from the operation of ships or aircraft devived derived by a resident of a one of the Contracting State States shall be taxable only in that State.
2. Notwithstanding the provisions of paragraph 1, such profits may be taxed in the other Contracting State where they are profits from operations of ships or aircraft confined solely to places in that other State.
3. The provisions of paragraphs 1 and 2 shall apply in relation to the share of the profits from the operation of ships or aircraft derived by a resident of a Contracting State through participation in a pool service, in a joint transport operating organisation or in an international operating agency.
4. For the purposes of this Article, profits derived from the carriage by ships or aircraft of passengers, livestock, mail, goods or merchandise shipped in a one of the Contracting State States for discharge at another place in that State shall be treated as profits from operations of ships or aircraft confined solely to places in that State.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement