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ARTICLE 8
Profits of Shipping, Inland Waterways Transport and Air Transport Enterprises and Railways
(1) Notwithstanding the provisions of Article 7, paragraphs (1) to (6):
- (1) Profits from the operation of ships or 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) Profits from the operation of boats engaged in inland waterways transport shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(2) Paragraph (1) shall also apply to a railway of a Contracting State whose activities extend to the territory of the other State.