Direct Tax Avoidance Agreements

Thailand

Article 8

SHIPPING AND AIR TRANSPORT

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

2.     Income or profits derived by an enterprise of a Contracting State from the operation of ships in international traffic may be taxed in the other Contracting State, but the tax imposed in that other State shall be reduced by an amount equal to 50 per cent thereof.

3.      The term 'operation of ships or aircraft' shall mean business of transportation in international traffic of persons, mail, livestock or goods by the ships or aircraft  including-

(i) the incidental lease of ships or aircraft in connection with such transportation;

(ii) use, maintenance or rental of containers in connection with such transportation;  and

(iii) any other activity directly connected with such transportation.

4.     For the purposes of paragraphs 1 and 2, interest on funds directly connected with the operation of ships or aircraft in international traffic shall be regarded as income from the operation of such ships or aircraft.

5.     The provisions of paragraphs 1 and 2 shall also apply to income or profits from the participation in a pool, a joint business or an international operating agency.