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 9
Shipping and Air Transport
Notwithstanding the provisions of Article 7 of this Agreement:
- (1) Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the enterprise is a resident.
- (2) The provisions of paragraph 1 shall also apply to profits derived from the participation in a pool, a joint business or an international operating agency.