Article 8 - Profit from Aircraft & Ships - Japan

ARTICLE 8 1. Profits from the operation of aircraft in international traffic carried on by an enterprise of a Contracting State shall be taxable only in that Contracting State. 2. Profits from the operation of ships in international traffic carried on by an enterprise of a Contracting State shall be taxable only in that Contracting State. 3. Notwithstanding the provisions of paragraph 2, such profits may be taxed in the other Contracting State from which they are derived during a period of first ten taxable years or previous years , as the case may be, for which this Convention shall have effect provided that the tax so charged shall not exceed: (a) during the first five years, 50 per cent, (b) during the remaining five years, 25 per cent, of the tax otherwise imposed by the taxation law of that other Contracting State. 4. The provisions of the preceding paragraphs of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency. 5. The provisions of this Article shall, notwithstanding the provisions of Article 2, also apply to the enterprise tax in Japan and to any tax similar to the said enterprise tax if and when such a tax is imposed in India.