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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.


Sea and Air Transport

Notwithstanding the provisions of Article (8) of this Convention:

(1) Profits generated from the operation of ships or aircraft in international transport shall be taxable only in the Contracting State that includes the actual headquarters of the enterprise management.

(2) If the place of management of the enterprise is aboard a ship, such place is the ship registration port. In case of the absence of such port, the enterprise shall be considered existing in the Contracting State where the operator of the ship is resident.

(3) For the purposes of this article profits generated from the operation of ships, aircraft in international transport shall include:

  • (a) profits from the rental of ships or aircraft operating in international transport, with or without crew;
  • (b) profits from the use, maintenance or rental of containers including locomotives and any other equipment related to the transport of containers used to transport goods and merchandise.

(4) For UAE the provisions of paragraph (1) shall apply to profits resulting from:

  • (a) participating in a Union, a joint work or an international operation agency.
  • (b) profits from selling tickets on behalf of other enterprises.
  • (c) income from training plans.
  • (d) income from the sale of technical engineering to a third party.
  • (e) income generated from bank deposits, shares, stocks and other debt instruments.