Article 8 - Shipping and Air Transport - Ethiopia

ARTICLE 8 SHIPPING AND AIR TRANSPORT 1. Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 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 harbor of the ship is situated, or, if there is no such home harbor, in the Contracting State of which the operator of the ship is a resident. 3. For the purposes of this Article profits from the operation of ships or aircraft in international traffic shall include 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 use, maintenance or rental, as the case may be, is supplementary or incidental to the operation of ships or aircraft in international traffic. 4. For the purposes of this Article interest on investments directly connected with the operation of ships or aircraft in international traffic shall be regarded as profits derived from the operation of such ships or aircraft if they are integral to the carrying on of such business, and the provisions of Article 11 shall not apply in relation to such interest. 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. 6. It is understood that the provisions of this Article shall replace the provisions of the Agreement between the Government of the Republic of India and the Provincial Military Government of Socialist Ethiopia for the Avoidance of Double Taxation of Income of Enterprises Operating Aircraft signed on November 25, 1976.