Specific rules for the allocation of taxing jurisdiction in respect of shipping and air transport are found in several kinds of treaties. It is always contained in comprehensive income tax treaties. It is also frequently found in old treaties covering only shipping and air transportation, such as treaties with Algeria, Brazil, Cameroon, Iran, Lebanon, Saudi Arabia and Zaire.
The UK-Mauritius Treaty is typical of UK treaties following the OECD Model, as shown here:
‘8(1) Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
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