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Cyprus - San Marino Tax Treaty (as amended by 2017 protocol) — Orbitax Tax Hub

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

Shipping and Air Transport

(1) Profits derived by a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.

(2) For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall include profits derived from the rental of ships or aircraft on a full (time or voyage) basis. They shall also include profits derived from the rental of ships or aircraft on a bareboat basis, if such rental activities are ancillary to the activities described in paragraph 1.

(3) Profits of an enterprise of a Contracting State from the use, maintenance or rental of containers (including trailers, barges and related equipment for the transport of containers) that are ancillary to income from the operation of ships or aircraft in international traffic shall be treated for the purposes of paragraphs (1) and (2) as income from the operation of ships or aircraft in international traffic.

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