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
International Traffic
(1) Profits derived by an enterprise of a Contracting State from the operation of ships, aircraft or motor vehicles in international traffic shall be taxable in that Contracting State where the place of effective management of the enterprise is situated.
(2) If the place of effective management of a shipping enterprise is aboard a ship, then the place of effective management of the enterprise shall be deemed to be situated in the Contracting State in which the home harbor of the ship is situated or where the operator of the ship is a resident.