Direct Tax Avoidance Agreements

Syrian Arab republic

Article 8

INTERNATIONAL TRAFFIC

1. Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.

2. If the place o effective management of a shipping enterprise is aboare a ship then it shall be deemed to be situated in the Contracting State in which the home harbor of the ship is situated or, if there is no such home harbor, in the Contracting State of which the operator of the ship is a resident.

3. Profits derived by a transportation enterprise which is a resident of a Contracting State from the use, maintenance, or rental of containers (including trailers and other equipment for the transport of containers) used for the transport of goods or merchandise in international traffic which is incidental to its operation of ships or aircraft in international traffic, shall be taxable only in that Contracting State unless the containers are used solely within the other Contracting State.

4. For the purposes of this Article interest on investments directly connected with the operation of ships or aircraft in international traffic shall be regarded as profits derived from the operation of such ships or aircraft if they are integral to the carrying on of such business, and the provisions of Article 11 shall not apply in relation to such interest,

5. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or operating agency.