CHAPTER I - SCOPE OF THE AGREEMENT
CHAPTER II - DEFINITIONS
CHAPTER III - TAXATION OF INCOME
CHAPTER IV - TAXATION OF CAPITAL
CHAPTER V - METHODS FOR ELIMINATIO...
CHAPTER VI - SPECIAL PROVISIONS
CHAPTER VII - FINAL PROVISIONS
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) Profits of an enterprise of a Contracting State from the operation of boats engaged in inland waterways transport shall be taxable only in that State.
(3) For the purposes of this Article profits from the operation of ships or aircraft in international traffic or boats shall include profits from:
- (a) the occasional rental of ships, boats or aircraft on a bare-boat basis and
- (b) the use or rental of containers (including trailers and ancillary equipment used for transporting the containers),
if these activities pertain to the operation of ships or aircraft in international traffic or boats.
(4) The provisions of paragraph (1) shall also apply to profits from the participation in a pool, a joint business or an international operating agency.