- 1
- Income and profits from the operation of aircraft in international traffic shall be taxable only in the State in which the place of effective management of the enterprises is situated.
- 2
- Capital represented by aircraft operated in international traffic and by movable property pertaining to the operation of such aircraft shall be taxable only in the State in which the place of effective management of the enterprises is situated.
- 3
- Where a special agreement for the avoidance of double taxation with respect to taxes on income, profits and capital exists between the Contracting Parties the provisions of the latter shall prevail.