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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.


Shipping and Air Transport

(1) Profits derived by an enterprise which has its place of effective management in a Contracting State from the operation in international traffic of ships or aircraft shall be taxable only in that State.

(2) Notwithstanding the provisions of paragraph (1), profits from sources within a Contracting State derived by an enterprise which has its place of effective management in the other Contracting State from the operation of ships or aircraft in international traffic may also be taxed in the first-mentioned State but the tax so charged shall not exceed the lesser of:

  • (a) one and one-half per cent of the gross revenues derived from sources in that State; and
  • (b) the lowest rate that may be imposed on profits of the same kind derived under similar circumstances by a resident of a third State.

(3) 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.

(4) The provisions of paragraphs (1) and (2) shall also apply to profits derived from the participation in a pool, a joint business or an international operating agency.