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
(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) The provisions of this Convention shall not apply with regard to the charges, tolls or similar payments that might be charged upon crossing the Panama Canal.