Examples of Shipping and Air Transport in a sentence
This result is consistent with the general rule under Article 8 (Shipping and Air Transport) that confers exclusive taxing rights over international shipping and air transport income on the state of residence of the enterprise deriving such income.
The substantive taxing rules of the Convention relating to the taxation of income from transport, principally Article 8 (Shipping and Air Transport), therefore, would not apply to income from such carriage.
This result is consistent with the allocation of taxing rights under Article 8 (Shipping and Air Transport).
With reference to paragraph 2 of Article 8 (Shipping and Air Transport): it is understood that income earned by an enterprise from the inland transport of property or passengers within either Contracting State falls within Article 8 if the transport is undertaken as part of the international transport of property or passengers by the enterprise.
Notwithstanding paragraph 2 of this Article, Article 8 (Shipping and Air Transport), and paragraph 3 of Article 13 (Capital Gains) shall have effect from the date of entry into force of this Agreement.
However, the term “interest” does not include income dealt with in Article 8 (Shipping and Air Transport) or Article 10 (Dividends).
In view of the special nature of the SAS consortium and in view of the agency agreement as described above, the United States for purposes of Article 8 (Shipping and Air Transport) of the Convention shall treat all of the income earned by SAS, Inc., that is derived from the operation in international traffic of aircraft as the income of the SAS consortium.
For example, the taxation of income of international shipping and aircraft operations is governed by Article 8 (Shipping and Air Transport) and not by this Article.
The provisions of Article 8 (Shipping and Air Transport) shall not affect the provisions of the Agreement of December 29, 1987, between the Government of the United States of America and the Government of the Republic of Venezuela for the avoidance of double taxation with respect to shipping and air transport.
Thus, the capital to which each of paragraphs 1, 2 and 3 of the Article relate is subject to taxation in the same manner as is income from such capital under Articles 6 (Income from Real Property (Immovable Property)), 7 (Business Profits), 8 (Shipping and Air Transport) and 13 (Gains) of the Convention.