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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 8

Shipping and Air Transport

(1) Notwithstanding the provision of paragraph (1) of Article 7, profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic in the other Contracting State shall be taxable only in the first-mentioned Contracting State.

(2) For the purpose of this Article, profits from the operation of ships or aircraft in international traffic shall include:

  • (a) profits derived occasionally from the rental on a bareboat basis of ships or aircraft used in international traffic;
  • (b) profits derived from the use or rental of containers, if such profits are supplementary or incidental to the profits to which the provisions of paragraph (1) apply;
  • (c) interest on funds directly connected with such operation.

(3) The provisions of paragraphs (1) and (2) shall also apply to profits from the participation in a pool, a joint business or an international operating agency.