SHIPPING, INLAND WATERWAYS TRANSPORT AND AIR 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.
SHIPPING, INLAND WATERWAYS TRANSPORT 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) Profits of an enterprise of a Contracting State from the operation of boats engaged in inland waterways transport shall be taxable only in that State.
(3) For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall include:
(a) profits from the rental on a bareboat basis of ships 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 in international traffic.
(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.
SHIPPING, INLAND WATERWAYS TRANSPORT AND AIR TRANSPORT. 1. Profits of an enterprise 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. If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident.
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.
4. 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.
5. For the purposes of this Article, profits 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;
(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; and
(c) interest on funds connected with the operations of ships or aircraft; where such rental or such use, maintenance or rental, or such interest, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
SHIPPING, INLAND WATERWAYS TRANSPORT 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.
SHIPPING, INLAND WATERWAYS TRANSPORT AND AIR 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 in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(3) For the purposes of this Article profits from the operation of ships, boats or aircraft in international traffic shall include profits from the occasional
a) rental of ships, boats or aircraft on a bare-boat basis and
b) use or rental of containers (including trailers and ancillary equipment used for transporting the containers),
(4) 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.
(5) 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, INLAND WATERWAYS TRANSPORT AND AIR 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) For the purposes of this Article, profits from the operation of ships, aircraft or boats shall include income from
1. the occasional rental of ships, aircraft or boats on a bare-boat basis, and
2. the use or rental of containers (including trailers and ancillary equipment used for transporting the containers), if such income is attributable to the profits from the operation of ships, boats or aircraft.
(4) 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.
(5) 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, INLAND WATERWAYS TRANSPORT AND AIR 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 is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbor of the ship or boat is situated, or, if there is no such home harbor, 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.
SHIPPING, INLAND WATERWAYS TRANSPORT AND AIR 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 4. In so far as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary. The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.
SHIPPING, INLAND WATERWAYS TRANSPORT AND AIR 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. If the place of effective management of a shipping enterprise is aboard a ship, 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. 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, INLAND WATERWAYS TRANSPORT AND AIR TRANSPORT. 1. Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting Party 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 Party 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 Party in which the
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.
