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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

Shipping, Inland waterways transport and Air Traffic

(1) Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

(2) Where the place of effective management of a shipping enterprise is aboard a ship, then such enterprise shall be deemed to be situated in the Contracting State in which the home harbor of this ship is situated, or, if there is no such home harbor, in the Contracting State of which the operator of the ship is a resident.

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