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 from the operation of 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)
- (a) Profits derived from the operation of ships in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
- (b) Notwithstanding the provisions of sub-paragraph (a), such profits may be taxed in the other Contracting State from which they are derived provided that the tax so charged shall not exceed:
- (aa) during the first five fiscal years after the entry into force of this Agreement, 50%, and
- (bb) during the subsequent five fiscal years, 25%, of the tax otherwise imposed by the internal law of that State. Subsequently, only the provisions of sub-paragraph (a) shall be applicable.
(3) The provisions of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.