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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 of 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 provisions of paragraph (1) shall also apply to profits from the participation in a pool, a joint business or an international operating agency.

(3) In this Article:

  • (a) the term "profits" includes:
    • (i) gross receipts and revenues derived directly from the operation of ships or aircraft in international traffic; and
    • (ii) interest that is incidental to the operation of ships or aircraft in international traffic;
  • (b) the term "operation of ships or aircraft in international traffic" by an enterprise, 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 enterprise provided that such charter, rental or alienation is incidental to the operation by that enterprise of ships or aircraft in international traffic.