Article 8 - Shipping and air transport - Thailand (Old - Effective upto 31-3-2016)

Article 8 : Shipping and air transport 1. Income derived by an enterprise of a ContractingState from the operation of aircraft in international traffic shall be taxable only in that ContractingState. 2. Income derived by an enterprise of a ContractingState from the operation of ships in international traffic may be taxed in the other ContractingState, but the tax imposed in that other ContractingState shall be reduced by an amount equal to 50 per cent thereof. 3. The provisions of paragraphs 1 and 2 of this Article shall also apply to income from the participation in a pool, a joint business or an international operating agency engaged in the operation of aircraft or ships. 4. For the purposes of paragraphs 1 and 2, interest on funds connected with the operation of ships or aircraft in international traffic shall be regarded as income from the operation of such ships or aircraft. 5. The term "operation of ships or aircraft" shall mean business of transportation of persons, mail, livestock or goods by the ships or aircraft, including the incidental lease of ships or aircraft and any other activity directly connected with such transportation.