ARTICLE 8
U.S. Income Tax Treaty — germany tax treaty documents: germany.pdf · 2026-10-03 edition · updated 2026-10-04 · United States
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.
Profits of an enterprise of a Contracting State from the use or rental of containers (including trailers, barges, and related equipment for the transport of containers) used in international traffic shall be taxable only in that State.
The provisions of paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business, or an international operating agency.
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