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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.

ARTICLE 9

Shipping and Air Transport

(1) Profits from the operation of aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

(2) Profits from the operation of ships in international traffic may be taxed in the State in which the place of effective management of the enterprise is situated. However, such profits arising in the other State may also be taxed in that State in accordance with its domestic law, but the tax so charged shall be reduced by fifty per cent.

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

  • (a) selling of tickets on behalf of another enterprise;
  • (b) income from selling of technical engineering to a third party;
  • (c) income deriving from deposits at the Bank, bonds, shares stocks and other debentures.

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

(5) The provisions of paragraphs 1 and 2 shall also apply to profits derived by such enterprises from the participation in a pool, a joint business or an international operating agency and to incidental income derived by such enterprises from the use of containers for the transport of goods or merchandise.