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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 from the operation of ships, aircraft or road vehicles in international traffic shall be taxable only in the Contracting State in which 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 it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident.

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

(4) Whenever after the entry into force of this Convention enterprises from different countries will agree to carry on an air transportation business together in the form of a consortium, the provisions of paragraph (1) shall apply to such part of the profits of the consortium as corresponds to the participation held in that consortium by an enterprise the place of effective management of which is situated in a Contracting State.