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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 of an enterprise of a Contracting State from the operation of ships, aircraft or road vehicles in international traffic shall be taxable only in the State in which its place of registration is situated. Such profits shall include profits derived by the enterprise from other activities, and, in particular, from the use or rental of containers used for the transport of goods or merchandise in international traffic, provided that such activities are incidental to the operation of ships, aircraft or road vehicles in international traffic by the enterprise.

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

(3) The provisions of this Article do not include the profits realized by an enterprise of a Contracting State through commissions on sales, in the other Contracting State, of travel tickets of ships, aircraft and road vehicles belonging to the other enterprises.