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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.


International Traffic

(1) Profits of an enterprise of a Contracting State from the operation of ships, aircraft, or road transport vehicles in international traffic shall be taxable only in the State in which the enterprise is registered and incorporated. 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 the above-mentioned means of transport 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 shall not apply to profits realized by an enterprise of a Contracting State through commissions on sales, in the other Contracting State, of travel tickets for aircraft and ships belonging to other enterprises.