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ARTICLE 8
Sea and Air Traffic
(1) Notwithstanding the provisions of Article 7, profits derived from the operation of ships or aircraft in international traffic, by a resident of a Contracting State, shall be taxable only in that State.
(2) The provisions of paragraph (1) of this Article, shall also apply to profits arising from the participation in a pool, a joint business or an international operating agency.
(3) In this Article:
- (a) the term "profits" means:
- (i) profits, net profits, gross income and income derived from the operation of ships or aircraft in international traffic;
- (ii) interest on amounts derived directly from activities that are incidental to the operation of ships or aircraft in international traffic;
- (iii) sale of tickets on behalf of an enterprise.
- (b) the term "operation of ships or aircraft" in international traffic for a person includes:
- (i) charter or leasing of ships or aircraft;
- (ii) leasing of containers and related equipment;
- (iii) alienation of ships or aircraft, containers and related equipment.
by that person in such a manner that such charter, leasing or alienation are related to the operation of ships or aircraft in international traffic.