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Article 9 - Shipping - PhilippinesExtract Article 9 : Shipping - 1. Profits derived by an enterprise of a Contracting State from the operation of ships in international traffic shall be taxable in that State. 2. Notwithstanding the provisions of paragraph 1, profits from sources within a Contracting State derived by an enterprise of the other ContractingState from the operation of ships in international traffic may be taxed in the first-mentioned State in accordance with its domestic law, but the tax so charged shall be reduced by forty per cent. In no case, however, shall the tax so charged exceed the lowest rate of Philippine tax that may be impose on profits of the same kind derived under similar circumstances by a resident of a third State. 3. 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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