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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.



(1) As an exception to the provisions of Article 7, profits from the operation of ships or aircraft in international transport shall be taxable only in the State where the actual management center exists.

(2) If the actual headquarters of management of a navigational maritime establishment is on board of a ship, this headquarters shall be deemed located in the Contracting State where the port of the ship is. If there is no port, it shall be deemed located in the state in which the operator of the ship is resident.

(3) The provisions of paragraph (1) hereof shall also apply to profits from the participation in a pool, a joint business or an international operating agency.

(4) The profits and revenues resulted from the operation of ships or airplanes in the international transport include:

  • (a) Revenues of ticket sales on behalf of another transport enterprise provided that it is linked directly to the trips on board of the ships or airplanes operated by the enterprise in the international transport or it is a complement to its sales.
  • (b) Revenues of international transport enterprise investments in bonds, shares and other debt instruments, provided that these investments are part and parcel of the operation of ships and airplanes in the international transport in the contracting state and closely and directly connected to such operation.