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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.


Air Transport

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

(2) For the purposes of this Article profits from the operation of aircraft in international traffic include profits from the rental on a bareboat basis of 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; and
  • (c) income deriving from deposits at the bank, bonds, shares, stocks and other debentures.

(4) For greater certainty Article 8 shall not be applied on the operation of aircrafts in international traffic.