ARTICLE 9
U.S. Income Tax Treaty — Indonesia Income Tax Treaty - 1988 · 2026-10-03 edition · updated 2026-10-04 · United States
Shipping and Air Transport
(1) Notwithstanding Article 8 (Business Profits), a resident of a Contracting State shall be exempt from taxation by the other Contracting State with respect to income derived by that resident from the operation of ships or aircraft in international traffic.
(2) For the purposes of paragraph (1), income from the operation of ships or aircraft in international traffic includes:
(a) income from the rental of ships or aircraft in international traffic on a full basis;
(b) income from the rental of aircraft on a bareboat basis if the aircraft is operated in international traffic;
(c) income from the rental of ships on a bareboat basis if the ship is operated in international traffic and the lessee is not a resident of the other Contracting State or a permanent establishment in that other State; and
(d) income from the use or maintenance of containers (and related equipment for the transport of containers) used in international traffic if such income is incidental to the income described in paragraph (1).
(3) Notwithstanding Article 14 (Capital Gains), gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic or containers (and related equipment for the transport of containers) used in international traffic shall be taxable only in that State.
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