(1) Profits from the operation of ships or aircraft in international
traffic carried on by an enterprise of a Contracting State shall be
taxable only in that Contracting State.
(2) For the purposes of this Article, profits from the operation
of ships or aircraft in international traffic include:
a) profits from the rental on a bareboat basis of ships or aircraft;
and
b) profits from the use, maintenance or rental of containers
(including trailers and related equipment for the transport of
containers) used for the transport of goods or merchandise;
where such rental or such use, maintenance or rental, as the
case may be, is incidental to the operation of ships or aircraft in
international traffic.
(3) The provisions of the preceding paragraphs of this Article
shall also apply to profits from the participation in a pool, a joint
business or an international operating agency.
Citation to select or copy
Germany / Japan; BGBl. 2016 II S. 956; edition de-japan-2016-base | BGBl. 2016 II S. 956 | Signed: 2015-12-17 | Gazette publication: 2016-07-25; article 8; English; unreviewed source text, current applicability unverified; /editions/de-japan-2016-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-japan-2016-base | BGBl. 2016 II S. 956 | Signed: 2015-12-17 | Gazette publication: 2016-07-25
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2016-07-25
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2015-12-17
Edition notes and known limitations
Original source edition; not a verified current-law consolidation. Unknown. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. 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.
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. 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): BEPS-MLI; general application from: 2026-01-01
This source supplies German and English versions. The signing clause also identifies Japanese as authentic; that third version is NOT present in this reader. 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-japan-2016-base/. PDF page links identify pages, not verified paragraph correspondence.