DT7306 - DT: France: double taxation agreement, Article 7: Shipping and air transport

This agreement applies for periods before the new comprehensive agreement has effect (see DT7250).

(1) Profits which a resident of one of the Contracting States derives from the operation of ships or aircraft in international traffic shall be taxable only in that State.

(2) Where profits within paragraph (1) of this Article are derived by a resident of a Contracting State from participation in a pool, a joint business or an international operating agency, the profits attributable to that resident shall be taxable only in the Contracting State of which he is a resident.