Common use of AVOIDANCE OF DOUBLE TAXATION Clause in Contracts

AVOIDANCE OF DOUBLE TAXATION. (1) Income and profits derived from the operation of aircraft in international traffic by an airline of one Contracting Party, including participation in a pool service, a joint air transport operation or an international operating agency, which are subject to tax in the area of that Contracting Party shall be exempt from income tax, profits tax and all other taxes on income and profits imposed in the area of the other Contracting Party. (2) Capital and assets of an airline of one Contracting Party relating to the operation of aircraft in international traffic shall be exempt from taxes on capital and assets imposed in the area of the other Contracting Party. (3) Gains from the alienation of aircraft operated in international traffic and movable property pertaining to the operation of such aircraft which are received by an airline of one Contracting Party, the income and profits of which according to paragraph (1) are taxable only in the area of that Contracting Party, shall be exempt from any tax on gains imposed in the area of the other Contracting Party. (4) For the purposes of this Article: (a) the term “income and profits” includes revenues and gross receipts from the operation of aircraft for the carriage of persons, livestock, goods, mail or merchandise in international traffic including: (i) the charter or rental of aircraft if such charter or rental is incidental to the operation of aircraft in international traffic; (ii) the sale of tickets or similar documents, and the provision of services connected with such carriage, for the airline itself or for other airlines, but in the latter case only if such sales or provisions of services are incidental to the operation of aircraft in international traffic; and (iii) interest on funds directly connected with the operation of aircraft in international traffic;

AVOIDANCE OF DOUBLE TAXATION. (1) Income and or profits derived from the operation of aircraft in international traffic by an airline of one Contracting Party, including participation in a pool service, a joint air transport operation or an international operating agency, which are subject to tax in the area of that Contracting Party shall be exempt from income tax, profits tax and all other taxes on income and or profits imposed in the area of the other Contracting Party. (2) Capital and assets of an airline of one Contracting Party relating to the operation of aircraft in international traffic shall be exempt from taxes of every kind and description on capital and assets imposed in the area of the other Contracting Party. (3) Gains from the alienation of aircraft operated in international traffic and movable property pertaining to the operation of such aircraft which are received by an airline of one Contracting Party, the income and profits of which according to paragraph (1) are taxable only in the area of that Contracting Party, Party shall be exempt from any tax on gains imposed in the area of the other Contracting Party. (4) For the purposes of this Article: (a) the term “income and or profits” includes revenues and gross receipts from the operation of aircraft for the carriage of persons, livestock, goods, mail or merchandise in international traffic including: (i) the charter or rental of aircraft if such charter or rental is incidental to the operation of aircraft in international trafficaircraft; (ii) the sale of tickets or similar documents, and the provision of services connected with such carriage, either for the airline itself or for any other airlines, but in the latter case only if such sales or provisions of services are incidental to the operation of aircraft in international trafficairline; and (iii) interest on funds directly connected with the operation of aircraft in international traffic;