(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) 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 ancillary
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 inter -
national operating agency.
de-costa-rica-2014-base | BGBl. 2014 II S. 917 | signed 2014-02-13 | published 2014-11-26 | Signed: 2014-02-13 | Gazette publication: 2014-11-26
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, multilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
Native German and English source transcriptions only. The signing clause names German, Spanish and English as authentic, with English prevailing on divergent interpretation of German/Spanish. Spanish is NOT printed as treaty text in this retained PDF and is NOT supplied here; no translation or global unavailability claim. Original signature 2014-02-13; gazette publication 2014-11-26; not current consolidated law. No qualified human wording review, legal review, current-law or publication approval. 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-costa-rica-2014-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2014-02-13; consent law 2014-11-20; gazette publication 2014-11-26. Edition ID year is not a signature date. Treaty entry into force: 2016-08-10. Roster general application: 2017-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 10. August 2016. 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.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Costa Rica R-P V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. 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.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2014 II S. 917 | de-costa-rica-2014-base | de-costa-rica-2014-base | BGBl. 2014 II S. 917 | signed 2014-02-13 | published 2014-11-26 | Signed: 2014-02-13 | Gazette publication: 2014-11-26 | Article 8 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-costa-rica-2014-base/en/articles/article-8/
Source, edition and limits
Source edition
de-costa-rica-2014-base | BGBl. 2014 II S. 917 | signed 2014-02-13 | published 2014-11-26 | Signed: 2014-02-13 | Gazette publication: 2014-11-26
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, multilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
Native German and English source transcriptions only. The signing clause names German, Spanish and English as authentic, with English prevailing on divergent interpretation of German/Spanish. Spanish is NOT printed as treaty text in this retained PDF and is NOT supplied here; no translation or global unavailability claim. Original signature 2014-02-13; gazette publication 2014-11-26; not current consolidated law. No qualified human wording review, legal review, current-law or publication approval. 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-costa-rica-2014-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2014-02-13; consent law 2014-11-20; gazette publication 2014-11-26. Edition ID year is not a signature date. Treaty entry into force: 2016-08-10. Roster general application: 2017-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 10. August 2016. 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.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Costa Rica R-P V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. 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.
Text language and status
en · authentic-language-transcription · machine-transcription