background image
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Shipping and Air Transport

Notwithstanding the provisions of Article 7 of this Agreement:

(1) Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State.

(2) For the purposes of this Article profit from the operation of ships or aircraft in international traffic include profits from the rental on a bareboat basis of ships or aircraft.

(3) The provisions of paragraph (1) shall also apply to profits derived from:

  • (a) the participation in a pool, a joint business or an international operating agency;
  • (b) selling of tickets on behalf of another enterprise;
  • (c) income from training schemes;
  • (d) income driving from deposits at the Bank for the transactional purposes.

(4) If the place of effective management of a shipping enterprise or of an inland waterways traffic enterprise is abode a ship or boat, than it shall be deemed to be situated in the Contracting State in which the home harbour of the ship or boat is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident.