Shipping and air transport

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..... national traffic may be taxed in the first mentioned State, but the tax so charged shall be reduced by an amount equal to 50 per cent thereof. 3. 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 harbour of the ship is situated, or, if there is no such home harbour, in the Contracting St .....

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..... 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. 6. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. - - sta .....

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