Air Transport
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....se of one of the Contracting States shall not be taxed in the other Contracting State. 2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint busines....
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.... the owners or lessees or charterers of aircraft, including the sale of tickets for such transportation on behalf of other enterprises, the incidental lease of aircraft and any other activity directly....
TaxTMI