INTERNATIONAL TRANSPORT. (1) Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. (2) Profits from the operation of boats engaged in inland waterways transport shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. (3) If the place of effective management of a shipping enterprise or of an inland waterways transport enterprise is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship or boat is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident. (4) 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: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
INTERNATIONAL TRANSPORT. (1) Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(2) Profits from the operation of boats engaged in inland waterways transport shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(3) If the place of effective management of a shipping enterprise or of an inland waterways transport enterprise is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship or boat is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident.
(4) The provisions of paragraph 1 (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: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
INTERNATIONAL TRANSPORT. (1) Profits from the operation of ships ships, aircraft, rail or aircraft road vehicle in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(2) Profits from the operation of boats engaged in inland waterways transport shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(3) If the place of effective management of a shipping enterprise or of an inland waterways transport enterprise is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship or boat is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident.
(4) The provisions of paragraph 1 (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: Agreement Between the Government of the Grand Duchy of Luxembourg and the Government of the Republic of Botswana for the Elimination of Double Taxation, Double Taxation Avoidance Agreement
INTERNATIONAL TRANSPORT. (1) . Profits from the operation of ships ships, aircraft or aircraft road transport 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) . Profits from the operation of boats boats, engaged in inland waterways waterway transport shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(3) . If the place of effective management of a shipping enterprise or of an inland waterways transport enterprise is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship or boat is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident.
(4) . 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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INTERNATIONAL TRANSPORT. (1) . Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(2) Profits from the operation of boats engaged in inland waterways transport shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(3) . If the place of effective management of a an international shipping enterprise or of an inland waterways transport enterprise is aboard a ship or boatship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship or boat is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident.
(3. Profits from the operation of rail 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.
4) . The provisions of paragraph paragraphs 1 and 3 shall also likewise apply to the profits derived from the participation in a pool, a joint business or an international operating agency.
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INTERNATIONAL TRANSPORT. (1) . Profits from the operation of ships ships, aircraft or aircraft 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) . Profits from the operation of boats engaged in inland waterways transport shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(3) . If the place of effective management of a shipping enterprise or of an inland waterways transport enterprise is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship or boat is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident.
(4) . 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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