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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

Notwithstanding the provisions of Article 7 of this Agreement:

  • (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 place of effective management.
  • (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) For the purposes of this Article profits from the operation of ships or aircraft in international traffic include:
    • (a) profits from the rental on a bareboat basis of ships or aircraft;
    • (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;
  • (4) The provisions of paragraph 1 shall also apply to profits derived from:
    • (1) The participation in a pool, a joint business or an international operating agency but only to so much of the profits so derived as is attributable to the participant in proportion to its share in the joint operation;
    • (2) Selling of tickets on behalf of another enterprise;
    • (3) Income from training schemes;
    • (4) Income from selling of technical engineering to a third party.
    • (5) Income deriving from deposits at the Bank, bonds. Shares stocks and other debentures providing that these activities are incidental on ancillary to the operation of ships or aircrafts operating in the international traffics.