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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

International Traffic

Notwithstanding the provisions of Article 7 of this Agreement:

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

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

  • (a) profits from the rental on a bareboat basis of ships, aircraft or road vehicle;
  • (b) profits from the use, maintenance or rental of containers, including trailers and related equipment for the transport of containers, used for the transport of goods or merchandise.

(3) The provisions of paragraph (1) shall also apply to profits derived from:

  • (1) The participation in a pool, a joint business or an international operating agency.
  • (2) selling of tickets on behalf of another enterprise
  • (3) income from training schemes
  • (4) Income from selling of technical engineering to a third party.
  • (5) Income deriving from deposits at the bank, bonds. Shares stocks and other debentures.