INTERNATIONAL TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships, aircraft or rail or road transport vehicles in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits from the operation of ships, aircraft or rail or road transport vehicles in international traffic shall include: (a) profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic, (b) profits derived from the rental of rail or road transport vehicles, (c) profits derived from the use or rental of containers, if such profits are incidental to the profits to which the provisions of paragraph 1 apply. 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.
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Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
INTERNATIONAL TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships, aircraft or rail or road transport vehicles in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits from the operation of ships, aircraft or rail or road transport vehicles in international traffic shall include:
(a) profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic,
(b) profits derived from the use or rental of rail or road transport vehicles,containers
(c) profits derived from the use or rental of containersrail or road transport vehicles, if such profits are incidental to the profits to which the provisions of paragraph 1 apply.
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.
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Samples: Double Taxation Agreement
INTERNATIONAL TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships, aircraft aircraft, or road or rail or road transport vehicles in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits from the operation of ships, aircraft aircraft, or road or rail or road transport vehicles in international traffic shall include:
(a) profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic,
(b) profits derived from the use or rental of rail or road transport vehicles,containers, and
(c) profits derived from the use or rental of containersroad or rail transport vehicles, if such profits are incidental to the profits to which the provisions of paragraph 1 of this Article 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.
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INTERNATIONAL TRANSPORT. β
1. Profits of an enterprise of a Contracting State from the operation of ships, aircraft or rail or road transport vehicles in international traffic shall be taxable only in that State.
2. For the purposes of this Article, profits from the operation of ships, aircraft or rail or road transport vehicles in international traffic shall include:
(a) profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic,;
(b) profits derived from the rental or lease of rail or road transport vehicles,;
(c) profits derived from the use use, rental or rental lease of containers, if such profits are incidental to the profits to which the provisions of paragraph 1 apply.
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.
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