Common use of SHIPPING, INLAND WATERWAYS TRANSPORT AND AIR TRANSPORT Clause in Contracts

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 of a Contracting State territory from the operation of ships or aircraft in international traffic shall be taxable only in that Stateterritory. (2) . Profits of an enterprise of a Contracting State territory from the operation of boats engaged in inland waterways transport shall be taxable only in that Stateterritory. (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 full (time or voyage) basis or a bareboat basis of ships and 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 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.