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
Ships and Aircraft
(1) Profits derived from the operation in international traffic of ships and aircraft in international traffic shall be taxable only in the Contracting State where the place of effective management is situated.
(2) The provisions of paragraph (1) shall also apply to profits derived by an enterprise operating ships or aircraft in international traffic, in a pool, a joint business, or an international operating agency.