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 8
Shipping and Air Transport
(1) Profits from the operation in international traffic of ships or aircraft shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(2) Where the place of effective management of a shipping enterprise is aboard a ship, then such enterprise shall be deemed to be situated in the Contracting State in which the home harbour of this 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.
(3) The provisions of paragraph (1) of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.