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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 from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

(2) If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident.

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

(4) The provisions of paragraph 1 shall also apply to the following income from the operations of aircraft in international traffic:

  • (a) income from the sale of tickets on behalf of an aircraft enterprise;
  • (b) income from selling of engineering services to a third party and any other income arising from other technical services which are incidental to the operation of airlines in international traffic;
  • (c) interest on cash deposits and income derived from stock, bonds and shares provided that such income is incidental to the operations of airlines and constitutes an integral part of the operation of airlines in international traffic.