DT5957 - DT: Denmark: double taxation agreement, Article 8: Shipping and air transport
- Profits of an enterprise of a Contracting State from the
operation of ships or aircraft in international traffic shall be
taxable only in that State.
- For the purposes of this Article, profits from the operation of
ships or aircraft in international traffic include:
- profits from the rental on a bareboat basis of ships or
aircraft; and
- 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.
- The provisions of paragraphs (1) and (2) of this Article shall
also apply to profits from the participation in a pool, a joint
business or an international operating agency, but only to so much
of the profits so derived as is attributable to the participant in
proportion to its share in the joint operation.
- With respect to profits derived by the Danish, Norwegian and
Swedish air transport consortium, known as the Scandanavian
Airlines System (SAS), the provisions of paragraphs (1), (2) and
(3) of this Article shall apply only to such proportion of the
profits as corresponds to the participation in that consortium by
Det Danske Luftfartsselskab (DDL), the Danish partner of the
Scandanavian Airlines System (SAS).
