DT18057 - DT: Sweden: double taxation agreement, Article 8: Shipping and air transport

(1) Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

(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 harbour of the ship is situated, or, if there is no such home harbour, in the State of which the operator of the ship is a resident.

(3) Where profits within paragraph (1) of this Article are derived by an enterprise from participation in a pool, a joint business or an international operating agency, the profits attributable to that enterprise shall be taxable only in the Contracting State in which the place of effective management of that enterprise is situated. For the purposes of this paragraph the expression `a pool, a joint business or an international operating agency` shall not include a person, as defined in Article 3 of this Convention.

(4) With respect to profits derived by the Danish, Norwegian and Swedish air transport consortium, known as the Scandinavian Airlines System (SAS), the provisions of paragraphs (1) and (3) of this Article shall only apply to such part of the profits as corresponds to the shareholding in the consortium held by AB Aerotransport (ABA), the Swedish partner of Scandinavian Airlines System (SAS).