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
Shipping and Air Transport
(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) 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) The provisions of this Article shall also apply to taxes levied on the basis of the gross receipts in respect of the carriage of passengers and cargo in international traffic.