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Article 8 - International traffic - BelarusExtract Article 8 : International traffic - 1. Profits of an enterprise of a ContractingState from the operation of ships or aircraft in international traffic, as the case may be, shall be taxable only in that State. 2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. 3. For the purposes of this article, interest on funds 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, and the provisions of Article 11 shall not apply in relation to such interest. 4. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall mean profits derived by an enterprise from the transportation by sea or air, respectively, of passengers, mail, livestock, goods or merchandise carried on by the owners or lessees or charterers of ships or aircraft. This will also include : (a) the sale of tickets for such transportation on behalf of other enterprises; (b) the use, maintenance, or rental of containers (including trailers, barges, and related equipment for the transportation of containers) used in connection with the operation of ships or aircraft in international traffic; (c) the rental of ships or aircraft incidental to the operation of ships or aircraft in international traffic; and (d) other activity directly connected with operation of ships or aircraft in international traffic.
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