DT6507 - DT: Egypt: 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 or boat, it shall be deemed to be in the Contracting State in which the home harbour of the ship or boat is situated or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident.

  3. The provisions of this Article shall likewise apply to the share in respect of participation in shipping or aircraft pools of any kind by such an enterprise engaged in shipping or air transport.