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ARTICLE 9

U.S. Income Tax Treaty — egypt tax treaty documents: egypt.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Shipping and Air Transport

(1) Notwithstanding Article 8 (Business Profits), profits derived by a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State.

(2) For purposes of this Article, income derived from the operation in international traffic of ships or aircraft does not include dividends received by a person by virtue of an ownership interest in a corporation engaged in the operation of ships or aircraft in international traffic, and includes (a) Income derived from the rental of ships or aircraft operated in international traffic if such rental income is incidental to other income described in paragraph (1); and

(b) Income derived from the use, maintenance, and lease of (i) Containers, (ii) Trailers for the inland transport of containers, and (iii) Other related equipment in connection with the operation by the resident in international traffic of ships or aircraft described in paragraph (1).

(3) The existing exemption of United States air transport enterprises afforded by Decree of the Egyptian Council of Ministers shall cease to have effect upon the entry into force of this Convention.

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▸Contents — U.S. Income Tax Treaty — egypt tax treaty documents: egypt.pdf
U.S. Income Tax Treaty — egypt tax treaty documents: egypt.pdf

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