(1) Profits from the operation of ships or aircraft in interna-
tional traffic shall be taxable only in the Contracting State in
which the place of effective management of the enterprise is sit-
uated.
(2) For the purposes of this Article the terms “profits from the
operation of ships or aircraft in international traffic” shall include
profits from
a) the occasional rental of ships or aircraft on a bare-boat
basis and
b) the use or rental of containers (including trailers and ancil-
lary equipment used for transporting the containers),
if these activities pertain to the operation of ships or aircraft in
international traffic.
(3) If the place of effective management of a shipping enter-
prise is aboard a ship, then it shall be deemed to be situated in
the Contracting State in which the home harbour of the ship is
situated, or, if there is no such home harbour, in the Contracting
State of which the operator of the ship is a resident.
(4) The provisions of paragraph 1 shall also apply to profits
from the participation in a pool, a joint business or an interna-
tional operating agency.
Citation to select or copy
Germany / Syria; BGBl. 2010 II S. 1359; edition de-syria-2010-base | BGBl. 2010 II S. 1359 | signed 2010-02-17 | published 2010-11-23 | Signed: 2010-02-17 | Gazette publication: 2010-11-23; article 8; English; unreviewed source text, current applicability unverified; /editions/de-syria-2010-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-syria-2010-base | BGBl. 2010 II S. 1359 | signed 2010-02-17 | published 2010-11-23 | Signed: 2010-02-17 | Gazette publication: 2010-11-23
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2010-11-23
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2010-02-17
Edition notes and known limitations
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2010-02-17; consent law 2010-11-18; gazette publication 2010-11-23. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2011-01-01 (not a universal tax-specific rule). Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. 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.
Printed signature protocol retained separately and not merged into articles. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated 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.
This source supplies German and English versions. The signing clause also identifies Arabic as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. 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-syria-2010-base/. PDF page links identify pages, not verified paragraph correspondence.