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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, Air and Land Transport

(1) Income from the operation of ships, aircraft or road vehicles in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

(2) If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such harbour, in the Contracting State of which the operator of the ship is resident.

(3) For the purpose of this Article, income from the operation in international traffic of ships and boats or aircraft includes income derived from the rental on a full or bareboat basis of ships and boats or aircraft if operated in international traffic by the lessee or if such rental income is incidental to other income described in paragraph (1).

(4) Income of an enterprise of a Contracting State from the use, maintenance, or rental of containers (including trailers, barges, and related equipment for the transport of containers) used for the transport in international traffic of goods or merchandise shall be taxable only in that State.

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