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 of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2) The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business, or an international operating agency but only to so much of the profits so derived as is attributable to the participant in proportion to its share in the joint operation.