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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.


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 this Article shall also apply to:

  • (a) profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic,
  • (b) profits derived from the use or rental of containers,

if such profits are incidental to the profits to which the provisions of paragraph 1 apply.

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