- 1
- Income and profits from the operation of aircraft in international air transportation shall be taxable only in the State in which the place of effective management of the Designated Airline is situated. However, this does not apply to the sales of Air Services by the Designated Airline(s) of one Party or its agents in the Territory of the other Party, which sales shall, in conformity with local fiscal legislation, be subject to the same conditions applicable to other Airlines selling Air Services in the Territory of the other Party.
- 2
- Capital represented by aircraft operated in international traffic and by moveable property pertaining to the operation of such aircraft shall be taxable only in the State in which the place of effective management of the Designated Airline is situated.
- 3
- The provisions of paragraph 1 of this Article shall also apply to income and profits from the participation in a pool, a joint business, a cooperative marketing arrangement or an international operating agency.
- 4
- If an agreement between the Parties on avoidance of double taxation and the prevention of fiscal evasion on income and on capital in which air transport is addressed envisages procedures different from those referred to in paragraphs 1-4 of this Article, the provisions of the agreement on avoidance of double taxation on income and on capital shall be applicable.
