INTERNATIONAL TRAFFIC. 1. Profits of the enterprise of a Contracting State from the operation of ships, boats, aircraft, railway or road vehicles in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits from the operation of ships, boats, aircraft, railway or road vehicles in international traffic also include profits from the rental on a bareboat basis of ships, boats, aircraft, railway or road vehicles when used in international traffic, where profits from such rental are incidental to the profits referred to in paragraph 1. 3. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits of the derived by an enterprise of a Contracting State from the operation of ships, boats, aircraft, railway boats or road vehicles aircraft in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits from the operation of ships, boats, aircraft, railway boats or road vehicles aircraft in international traffic also include traffic, derived by an enterprise of a Contracting State, include:
a) profits from the rental on a bareboat basis of ships, boatsboats or aircraft;
b) profits from the rental of containers and related equipment, aircraftif that rental is incidental to the operation of ships, railway boats or road vehicles when used aircraft by that enterprise in international traffic, where profits from such rental are incidental to the profits referred to in paragraph 1.
3. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits of an enterprise from the enterprise of a Contracting State from the operation of ships, boats, aircraft, railway ships or road vehicles aircraft in international traffic and from the use 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.
2. For the purposes of this Article, profits from the operation of ships, boats, aircraft, railway ships or road vehicles aircraft in international traffic also shall include profits derived from the rental on a bareboat bare boat basis of ships, boats, aircraft, railway ships or road vehicles when aircraft used in international traffic, where if such profits from such rental are arc incidental to the profits referred to in which the provisions of paragraph 11 apply.
3. The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract
INTERNATIONAL TRAFFIC. 1. Profits of the an enterprise of a Contracting State from the operation of ships, boats, aircraft, road or railway or road vehicles in international traffic shall be taxable only in that State.
2. For the purposes Profits of this Articlean enterprise of a Contracting State from rental of aircraft, road or railway vehicles, or profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships, boats, aircraft, railway or road vehicles in international traffic also include profits from the rental on a bareboat basis such means of ships, boats, aircraft, railway or road vehicles when used transportation in international traffic, where profits from such rental are incidental to the profits referred to shall be taxable only in paragraph 1that State.
3. The provisions of paragraph paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
Appears in 1 contract