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 from the operation of ships or aircraft in international traffic shall be taxable only on the Contracting State in which the place of effective management of the enterprise is situated.
(2) The provisions of paragraph (1) shall likewise apply in respect of participations in pools, in a joint business or in an international operation agency of any kind by enterprises engaged in the operation of ships or aircraft in international traffic.