(a) Transportation beginning and ending in Puerto Rico. — Except as otherwise provided in this section, all transportation income attributable to transportation which begins and ends in Puerto Rico shall be treated as totally derived from sources within Puerto Rico.(b) Transportation having Puerto Rico connection. — There shall be treated as from sources in Puerto Rico, fifty percent (50%) of all transportation income attributable to transportation which:(1) Is not described in subsection (a), and(2) begins or ends in Puerto Rico.(c) Special rule in the case of cruises. — Gains, profits and income derived from the operation of passenger cruise ships by foreign corporations or partnerships shall be treated as income sourced outside Puerto Rico.(d) Transportation income. — For purposes of this subchapter, the term 'transportation income' means any gain, profit or income derived from or in connection with(1) the use or hiring (leasing for use by others) of a vessel or aircraft, or(2) the performance of services directly related to the use of a vessel or aircraft.(e) For purposes of subsection (d) of this section, the term 'vessel or aircraft' includes any container used in connection

performance of services directly related to the use of a vessel or aircraft.(e) For purposes of subsection (d) of this section, the term 'vessel or aircraft' includes any container used in connection with a vessel or aircraft. History —Jan. 31, 2011, No. 1, § 1035.07, retroactive to Jan. 1, 2011.