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Article III

Internal Revenue Bulletin 2000-22 · 2026-10-03 edition · updated 2026-10-04 · United States

SHIPPING AND AIR TRANSPORT

  1. Income derived from the international operation of a ship or ships or aircraft by a corporation organized in a Contracting Party and engaged in the international operation of a ship or ships or aircraft shall be exempt from tax by the other Contracting Party.
  2. In order for a corporation organized in a Contracting Party to claim benefits under this agreement, it must satisfy any ownership or public trading requirements, as well as any filing requirements, of the other Contracting Party.
  3. Corporations of a Contracting Party engaged in the international operation of aircraft include those airlines designated under the Air Transport Agreement between the Contracting Parties

May 30, 2000 1126 2000–22 I.R.B.

or whose flights are otherwise authorized by the civil aviation authority of the receiving Contracting Party.

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