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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 9

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 Contracting State.

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

  • (a) profits from rental on a bareboat basis of ships 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.

(3) The provisions of paragraph (1) shall also apply to profits derived from:

  • (a) the participation in a pool, a joint business or an international operating agency;
  • (b) selling of tickets on behalf of another enterprise;
  • (c) income from selling of technical engineering to a third Contracting State; and
  • (d) income deriving from deposits at the bank, bonds, shares, stocks and other debentures.