(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 are incidental to the operation of ships or air-
craft in international traffic.
(3) Paragraph 1 shall also apply to the share of the profits
from the operation of ships or aircraft through participation in a
pool, a joint business or an international operating agency.
de-malaysia-2010-base | BGBl. 2010 II S. 1310 | Signed: 2010-02-23 | Gazette publication: 2010-11-23
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Malaysian 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-malaysia-2010-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. 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.
Protocols and later instruments
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.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2010 II S. 1310 | de-malaysia-2010-base | de-malaysia-2010-base | BGBl. 2010 II S. 1310 | Signed: 2010-02-23 | Gazette publication: 2010-11-23 | Article 8 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-malaysia-2010-base/en/articles/article-8/
Source, edition and limits
Source edition
de-malaysia-2010-base | BGBl. 2010 II S. 1310 | Signed: 2010-02-23 | Gazette publication: 2010-11-23
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Malaysian 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-malaysia-2010-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. 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.
Protocols and later instruments
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.
Text language and status
en · authentic-language-transcription · machine-transcription