Article 8 - Shipping and Air Transport - Belgium

ARTICLE 8 SHIPPING AND AIR TRANSPORT 1. Income derived from the operation of ships or aircraft in international traffic by an enterprise of a Contracting State shall not be taxed in the other Contracting State. 2. For the purposes of this Article: (a) interest on funds directly connected with the operation of ships or aircraft in international traffic shall be regarded as income from the operation of such ships or aircraft and the provisions of Article 11 shall not apply in relation to such interest; accordingly, there will be no withholding tax on such income; (b) income derived from the operation of ships or aircraft in international traffic shall mean income derived by an enterprise described in paragraph 1 from the transportation by sea or air respectively of passengers, mail, livestock or goods carried on by the owners or lessees or charterers of ships or aircraft including (i) the sale of tickets for such transportation on behalf of other enterprises; (ii) any other activity directly connected with such transportation; (iii) the leasing of ships or aircraft on charter fully equipped, manned and supplied, or on a bare boat charter basis where the leasing is incidental to any activity directly connected with such transportation; (c) income derived from the operation of ships in international traffic includes income derived from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) in connection with the transportation of goods or merchandise in international traffic, where the income is derived from an activity which is incidental to any activity directly connected with such transportation. 3. The provisions of this Article shall also apply to income from the participation in a pool, a joint business or an international operating agency.