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Germany - Papua N Guinea Treaty (1995, not yet in force) — Orbitax Tax Hub

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.


Shipping and Air Transport

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

(2) Profits derived by an enterprise of a Contracting State from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) shall be taxable only in that State except if the profits are derived from a contract under which the container is used wholly or mainly in the other Contracting State. If the container is so used, the profits from that contract may be taxed in that State.

(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.