- 1
- Income and profits from the operation of aircraft in international traffic shall be taxable only in the State in which the Designated Airline is established.
- 2
- Gains from the alienation of aircraft operated in international traffic shall be taxable only in the State in which the Designated Airline is established.
- 3
- 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 Designated Airline is established.
- 4
- 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.
- 5
- If an agreement between the Contracting 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 paragraph 1- 4 of this Article, the provisions of the agreement on avoidance of double taxation on income or capital shall be applicable.
