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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.


International Traffic

(1) Profits derived by a resident of a Contracting State from the operation of ships, aircraft, road or railway vehicles in international traffic shall be taxable only in that State.

(2) Notwithstanding the provision of paragraph (3) of Article 12, for the purposes of this Convention, profits from the operation of ships or aircraft in international traffic include:

  • (a) profits from the rental on a bare boat basis of ships or aircraft and
  • (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods, 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 from the participation in a pool, a joint business or an international operating agency.