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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 from the operation of ships in international traffic shall be taxable only in that Contracting State in which the place of effective management of the enterprise is situated.

(2) If the place of effective management of a shipping enterprise is aboard a ship, its headquarters shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or in the absence of such home harbour, in the Contracting State of which the operator of the ship is a resident.

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