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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, Air and Land Transport

(1) Profits derived by an enterprise registered and having its headquarters (i.e., effective management) in a Contracting State from operation of ships, aircraft or land vehicles in international traffic shall be taxable only in that State.

(2) The provisions of paragraph (1) shall also apply to profits from the participation in a pool, a joint business or an international operating agency.

(3) For the purposes of this Article, interest on funds connected with the operation of ships, aircraft or land vehicles in international traffic shall be regarded as profits derived from the operation of such ship, aircraft or land vehicles, and the provisions of Article 11 shall not apply in relation to such interest.

(4) The term "operation of aircraft" shall mean business of transportation by air passengers, mail, livestock or goods carried on by the owners or lessees or charterers of aircraft, including the sale of tickets for such transportation on behalf of other enterprise, the incidental lease of aircraft and any other activity directly connected with such transportation.

(5) The term "operation of ships" shall include:

  • (a) the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) in connection with the transport of goods or merchandise in international traffic;
  • (b) rental on a full or bareboat basis of ships if operated in international traffic.