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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.


Sea and Air 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) Notwithstanding the provisions of paragraph (1) of this Article and of Article 7, profits arising from the operation of ships or aircraft for transporting passengers or merchandise exclusively between places situated in a Contracting State shall be taxable in that State.

(3) The provisions of paragraph (1) and (2) of this Article shall also apply to profits arising out of the participation in a pool, a joint business, or an international operating agency.

(4) Insofar as the profits realized by the Norwegian, Danish and Swedish Consortium of air traffic "Scandinavian Airlines System (SAS)" on the one hand and by the multinational company AIR-AFRICA on the other hand are concerned, the provisions of the preceding paragraphs (1), (2) and (3) of this Article shall only apply to the share of these companies attributed to the Norwegian associate of the SAS consortium "Det Norske Luftfartsselskap A/S (DNL)" on the one hand and to the Senegalese associate of the company AIR-AFRICA, the State of Senegal, on the other hand.