INTERNATIONAL 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.
INTERNATIONAL TRANSPORT. 01. 12. 01. Maritime 01. 12. 02. Overland 01. 12. 03. Air
INTERNATIONAL TRANSPORT. 01.12.01. Maritime 01.12.02. Overland 01.12.03. Air 01.13 Personnel 01.13.01. Expatriate staff
INTERNATIONAL TRANSPORT l. Profits from the operation of ships, aircraft or road vehicles in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
INTERNATIONAL TRANSPORT. 1. Profits from the operation or rental of ships, aircraft or rail or road transport vehicles in international traffic and the rental of containers and related equipment which is incidental to the operation of ships, aircraft or rail or road transport vehicles in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
INTERNATIONAL TRANSPORT. 1. Profits of an enterprise of a Contracting Party from the operation of aircraft in international traffic shall be taxable only in that Party.
INTERNATIONAL TRANSPORT. The income derived by shipping and air transport enterprises of a Contracting State from international traffic of goods and passengers shall be exempted from tax in the other Contracting State.
INTERNATIONAL TRANSPORT. 1 - The profits resulting from the operation of ships, planes, railways and road vehicles in international transport shall be subject to taxes only in the country where the headquarters of the actual management of the project is located.
INTERNATIONAL TRANSPORT. See treaty text. Not analysed.
INTERNATIONAL TRANSPORT. The profits of Singaporean resident entities which operate in the airline industry will be taxable only in Singapore (and vice versa for Cambodian resident entities). Importantly, there is an exception for the taxation of profits derived from the operation of ships in international traffic which may be taxed in both jurisdictions. However, the country in which the entity is not tax resident, may only tax these profits at 50% of the normal income tax rate. That means a Singaporean entity will only be subject to tax at a rate of 10% in Cambodia (i.e. 50% of Tax on Profits rate of 20%). Capital gains An interesting aspect of the DTA is the inclusion of a provision relating to the disposal of shares which derive greater than 50% of their value directly or indirectly from property situated in Cambodia (or vice versa, Singapore). In these circumstances, the gain from disposal will be taxable in the location of where that property is situated. The taxation of gains from immoveable property, and moveable property (in connection with a PE) shall be taxable in the jurisdiction of their location. All other gains will be taxable in the country of residence (including those relating to the alienation of ships or aircraft used in international traffic). Independent personal services Singaporean resident individuals who provide independent personal services (i.e. professional services or activities of an independent character) in Cambodia will be taxable in Singapore, and vice versa for Cambodian resident individuals. However, where such an individual maintains a fixed base in Singapore / Cambodia, respectively, or is present in that country for a period of 183 days in any 12 months, income derived from independent personal services may be taxed by that country. It is important that individuals providing independent professional services consider how the DTA may alter or affect the taxation of their income in these tax jurisdictions. The term “professional services’’ includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. Dependent personal services Employees of a company who are sent to work overseas in Methods for elimination of double taxation Double taxation in Cambodia shall be alleviated by the allowance of a tax credit for any tax suffered in Singapore (subject to certain limitations). A similar approach will be ...
