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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 Traffic

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

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

  • (a) profits occasionally derived from the lease of ships or aircraft used in international traffic;
  • (b) profits derived from the use or lease of containers and other connected equipment, provided such profits are complementary or ancillary in relation to the profits to which the provisions of paragraph (1) of this Article are applicable;

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