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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.


Shipping and Air Transport

(1) Income and profits derived by 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 provision of paragraph 1 shall also apply to the share of income and profits from the operation of ships or aircraft derived by a resident of a Contracting State through participation in a pool, a joint business or an international operating agency.

(3) In this Article:

  • (a) the term "profits" includes:
    • (i) interest derived from the deposits with any bank of any income or profit derived from the operation of ships or aircraft between the Contracting State.
  • (b) the term "operation of ships or aircraft" in international traffic by a person, includes:
    • (i) the charter or rental of ships or aircraft,
    • (ii) the rental of containers and related equipment, and
    • (iii) the alienation of ships, aircraft, containers and related equipment,
  • by that person provided that such charter, rental or alienation is incidental to the operation by that person of ships or aircraft in international traffic.