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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

International Traffic

Notwithstanding the provisions of Article 7 of this Agreement:

  • (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) For the purposes of this Article profits from the operation of ships or aircraft in international traffic include:
    • (1) the rental of a ship or aircraft on a bareboat charter basis;
    • (2) the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers),

by that enterprise where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.

(3) The provisions of paragraph (1) shall also apply to profits derived from:

  • (1) the participation in a pool, a joint business or an international operating agency;
  • (2) selling of tickets on behalf of another enterprise.

(4) Interest derived from bank deposits, income from bonds, shares, stocks and other debentures directly connected with the operation of ships or aircraft in international traffic shall be regarded as profit derived from the operation of ships or aircraft in international traffic, provided that these interest and income are incidental to the operation of ships or aircraft in international traffic, and the provisions of Article 11 shall not apply in relation to such interest and income.