Article 8 - Air transport - UAR (Egypt)

1 [ARTICLE 8 AIR TRANSPORT 1. Income derived from the operation of aircraft by an enterprise of one of the Contracting States shall not be taxed in the other Contracting State unless the aircraft is operated wholly or mainly between places within that other Contracting State. 2. Paragraph (1) shall likewise apply in respect of participations in pools of any kind by enterprises engaged in air transport. ******************* NOTES:- 1 . The Note dated 20-2-1969 exchanged between India and UAR set out the following understanding of the provision of this article read with article XXIX: The provisions of article VIII (Air Transport) of the said Convention being operative under the terms of article XXIX (Entry into force) of the Convention in the case of India, as respects income derived from operation of aircraft during any previous year beginning on or after the first day of January, 1961, and in the case of the United Arab Republic, as respects such income derived during any accounting period ending on or after the first day of January,1961; Where any taxes covered by this Convention have been paid or are payable in one of the Contracting States by a designated airline of the other Contracting States as respects such income derived by it during any previous year or accounting period aforesaid, the first-mentioned Contracting State shall refund such taxes to or, as the case may be, refrain from charging such taxes from the designated airline. The designated airline aforesaid shall, in the case of India, be the Air India, and in the case of the United Arab Republic, be the United Arab Airlines.