Encyclopedia
Profit from the operation of maritime or air vessels in international transportation
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Profit from the operation of maritime or air vessels in international transport includes: i) profit from the use, maintenance, or leasing of containers (including trailers, barges, or associated equipment for container transportation), used for transporting goods or products in international transport; and ii) profit obtained from the full lease of maritime or air vessels, and profit obtained from the lease of maritime or air vessels on a bareboat basis, provided that in the latter case such leasing profit is incidental and secondary to other profits from the operation of maritime or air vessels in international transport1.
Profit from the operation of sea or air vessels in international transport - includes profit from the leasing of sea or air vessels with crew (on time charter or voyage charter terms). It also includes profit received by a resident of the Contracting State engaged in the operation of sea or air vessels in international transport, from the leasing of sea or air vessels without crew, if such sea or air vessels are operated by the lessee in international transport2.
Convention between the Government of the Russian Federation and the Government of the Italian Republic on the avoidance of double taxation with respect to income and capital taxes and prevention of tax evasion, as amended on 15 February 1999, Article 30. ↩
Agreement between the Government of the Russian Federation and the Government of the United Mexican States on the Avoidance of Double Taxation with Respect to Income Taxes, as amended on 2008-08-11, art. 8. ↩
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