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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Trinidad and Tobago: double taxation agreement, Article 8: Shipping and air transport

(1) Profits from the operation of ships or aircraft in international traffic shall betaxable only in the Contracting State in which the place of effective management of theenterprise is situated.

(2) If the place of effective management of a shipping enterprise is aboard a ship, thenit shall be deemed to be situated in the Contracting State in which the home harbour ofthe ship is situated, or, if there is no such home harbour, in the Contracting State ofwhich the operator of the ship is a resident.

(3) The provisions of this Article shall also apply to profits derived from participationin a pool, a joint business or an international operating agency.