(1) Profits from the operation of ships or aircraft in internation-
al traffic shall be taxable only in the Contracting State in which
the place of effective management of the enterprise is situated.
(2) Profits from the operation of boats engaged in inland wa-
terways transport shall be taxable only in the Contracting State in
which the place of effective management of the enterprise is
situated.
(3) For the purposes of this Article profits from the operation of
ships, boats or aircraft in international traffic shall include profits
from
a) the occasional rental of ships, boats or aircraft on a bare-boat
basis and
b) the use or rental of containers (including trailers and ancillary
equipment used for transporting the containers),
if these activities pertain to the operation of ships, boats or air-
craft in international traffic.
(4) If the place of effective management of a shipping enter-
prise or of an inland waterways transport enterprise is aboard a
ship or boat, then it shall be deemed to be situated in the Con-
tracting State in which the home harbour of the ship or boat is
situated, or, if there is no such home harbour, in the Contracting
State of which the operator of the ship or boat is a resident.
(5) The provisions of paragraphs (1) and (2) shall also apply to
profits from the participation in a pool, a joint business or an in-
ternational operating agency.
Citation to select or copy
Cyprus / Germany; BGBl. 2011 II S. 1068; edition de-cyprus-2011-base | BGBl. 2011 II S. 1068 | Signed: 2011-02-18 | Gazette publication: 2011-11-07; article 8; English; unreviewed source text, current applicability unverified; /editions/de-cyprus-2011-base/en/articles/article-8/
Disclaimers
Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.
Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.
Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.
Noindex is not access control. This is a research preview, not a statement of authoritative or current law.
de-cyprus-2011-base | BGBl. 2011 II S. 1068 | Signed: 2011-02-18 | Gazette publication: 2011-11-07
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2011-11-07
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2011-02-18
Edition notes and known limitations
Original source edition; not a verified current-law consolidation. Original base edition only; current law NOT verified. Integral protocol retained separately, not merged into the final article. Later changes and 2026 developments are not exhaustively verified. KNOWN LATER AMENDMENT OMITTED: protocol signed 2021-02-19, entry 2021-12-08, general application 2022-01-01 per pinned audit; not incorporated. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Integral protocol retained separately, not merged into the final article. Later changes and 2026 developments are not exhaustively verified. KNOWN LATER AMENDMENT OMITTED: protocol signed 2021-02-19, entry 2021-12-08, general application 2022-01-01 per pinned audit; not incorporated. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2021-02-19; entry into force: 2021-12-08; general application from: 2022-01-01; limit: Exact tax-specific application remains for protocol review.
The original signing clause identifies German, Greek and English as authentic. Only German and English are supplied; the authentic Greek version is NOT included. The clause gives English precedence in divergent interpretation of the German and Greek texts. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-cyprus-2011-base/. PDF page links identify pages, not verified paragraph correspondence. Signed 2011-02-18; consent law 2011-11-01; Gazette publication 2011-11-07; treaty entry into force UNRESOLVED in pinned audit (retained official-article audit evidence); general application from 2012-01-01 (roster, not universal tax-specific start). Encoding-recovery method: only independently evidenced source font code00 /space Unicode mappings U+0007 to U+0020 changed in a separately hashed derivative. CFF blank glyphs, 278-unit advances, unchanged decoded page content streams and 21/21 identical page renders evidence this mapping. Word regrouping is logged; every nonspace character is conserved in sequence within its physical source line. No generated treaty wording and no OCR.