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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 and Air Transport

(1) Profits of an enterprise of a Contracting State, from the international operation of ships or aircraft shall be taxable only in that State where the place of effective management of the enterprise is situated.

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

(3) The provisions of paragraphs (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) Ships and aircraft mentioned in the preceding paragraphs refer, on the one hand, to the Gulf Air Company when the State of Qatar has a share in the capital of this company and in any other shipping or air transport company identified by the Government of the State of Qatar and, on the other hand, to the multinational Air Africa company where the State of Senegal has a share in the capital of this company and in any other shipping or air transport company identified by the Government of the Republic of Senegal.