DT6720.8 - DT: Estonia: 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 of an enterprise 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 by an enterprise 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.
