DT3660.8 - DT: Bolivia: double taxation agreement, SI 95 No.2707, 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. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:

  1. income from the rental on a bareboat basis of ships or aircraft; and

  2. profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise;

where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
  1. The provisions of paragraph (1) or (2) shall apply mutatis mutandis to participations of an enterprise operating ships or aircraft in international traffic in a pool, a joint business or other international operating agency.

  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 Contracting State of which the operator of the ship is a resident.