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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 operation of ships or aircraft in international traffic shall be taxable only in that State. Such profits shall include profits derived by the enterprise from the use or rental on a bareboat basis of ships, aircraft or containers when used in international traffic, provided that profits from such use or rental are incidental to the operation of ships or aircraft in international traffic.

(2) The provisions of paragraph 1 shall also apply to profits derived from the participation in 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 aircraft and ships belonging to other enterprises. In such case the provisions of Article 7 shall apply.