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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 generated from the operation of ships or aircrafts in international traffic shall be taxable only in the Contracting state that includes the actual "headquarters" of the enterprise management.

(2) For the purpose of this Article, the profits derived from the operation of ships or aircrafts in international traffic shall include the profits generated by the enterprise included in abovementioned paragraph (1) as well as the profits of maritime and airtime transport for passengers, post services, livestock and goods. They also include:

  • (a) renting or leasing ships or airplanes for such transport;
  • (b) renting containers or equipments required to be used in the operation of ships and aircrafts in the international traffic;
  • (c) profits resulting from the purchase of ships, aircrafts, containers and equipments of the enterprise that are used in the operation of international traffic;

(3) The provisions of paragraphs (1) and (2) of this Article shall apply to profits resulting from subscription in a federation, a shared enterprise or an international agency operating ships or aircrafts.

(4) The regulations of state-owned airspace transport corporations in both Contracting States shall be shared through the diplomatic channels.