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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) Profits derived by a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State.

(2) The provisions of paragraph (1) of this Article shall also apply to profits derived by a resident of a Contracting State from its participation in a pool, a joint business or an international operating agency.

(3) In this Article the term "profits" includes:

  • (a) the sale of passage tickets on behalf of other enterprises;
  • (b) the operation of a bus service connecting a town with its airport;
  • (c) advertising and commercial propaganda;
  • (d) transportation of goods by truck connecting a depot with a port or airport.