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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.

ARTICLE 8

International Transport

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

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