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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.


International Traffic

(1) Profits of an enterprise of a Contracting State from the operation of ships, boats, aircraft or road and railway vehicles in international traffic shall be taxable only in that Contracting State.

(2) For the purposes of this Article, profits from the operation of ships, boats or aircraft in international traffic also include:

  • (a) profits from the rental on a bareboat basis of ships, boats or aircraft; and
  • (b) profits from the use, maintenance or rental of containers, including trailers and related equipment for the transport of containers, used for the transport of goods or merchandise;

where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.