Common use of SHIPPING AND AIR TRANSPORT Clause in Contracts

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat basis of ships or aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat basis of ships or aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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 operation agency.

SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. 3. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits income from the rental on a bareboat basis lease of ships or aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), used for the transport of goods or merchandise; where such rental lease or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State derived from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat basis of ships or and aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits profit from the rental on a bareboat basis of ships or aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat basis of ships or aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic carried on by an enterprise of a Contracting State shall be taxable only in that Contracting State. 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat basis of ships or aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), ) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 3. The provisions of paragraph 1 the preceding paragraphs of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.

SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State Party from the operation of ships or aircraft in international traffic shall be taxable only in that State.Party 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat full (time, voyage or bareboat) basis of ships or aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), ) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 3. The provisions of paragraph 1 and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits [of an enterprise enterprise] from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat basis of ships or aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), ) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation by an enterprise of a Contracting State of ships or aircraft by the enterprise in international traffic. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State Party from the operation of ships or aircraft in international traffic shall be taxable only in that StateParty. 2. For the purposes purpose of this Article, profits of an enterprise from the operation in international traffic of ships or aircraft shall include in international traffic shall includeparticular: (a) profits derived from the rental or lease by the enterprise on a bareboat bare boat charter basis of ships or aircraft; andaircraft used in international traffic ; (b) profits derived from the use, maintenance maintenance, rental or rental lease of containers (including trailers and related equipment for by the transport of containers), used for the transport of goods or merchandiseenterprise; where such rental or lease profits or profits from such use, maintenance maintenance, rental, or rentallease, as the case may be, is are incidental to the operation of ships or aircraft by the enterprise profits described in international trafficparagraph 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic by an enterprise of a Contracting State shall be taxable only in that State.Contracting State.‌ 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat basis of ships or aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic carried on by an enterprise of a Contracting State shall be taxable only in that State. 2. For the purposes of this Article, Article the terms "profits of an enterprise from the operation of ships or aircraft in international traffic traffic" shall includeinclude profits from: (a) profits from the occasional rental of a ship or aircraft on a bareboat basis of ships or aircraftbare boat charter basis; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), ) used for the transport of goods or and merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic; and c) the rental of ships or aircraft fully equipped, manned and supplied. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat basis of ships or aircraft; andaircraft;and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), used for the transport of goods or merchandise; where such rental rental, use or such use, maintenance or rentalmaintenance, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of derived by an enterprise of a Contracting State Party from the operation of ships or aircraft in international traffic shall be taxable only in that StateParty. 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall includeinclude : (a) a. profits from the rental on a bareboat full (time, voyage or bareboat) basis of ships or aircraft; and (b) b. profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), ) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat basis of ships or aircraftaircraft in international traffic; and (b) profits from the use, maintenance or rental of containers in international traffic (including trailers and related equipment for the transport of containers), ) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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.

SHIPPING AND AIR TRANSPORT. 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits of an enterprise from the operation of ships or aircraft in international traffic shall include: (a) profits from the rental on a bareboat basis of ships or aircraft; and (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers), ) used for the transport of goods or merchandise; where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft by the enterprise in international traffic. 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, but only to so much of the profits so derived as is attributable to the participant in proportion to its share in the joint operation.