Shipping and air transport
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....terprise is situated. 2. Notwithstanding the provisions of paragraph (1), profits derived from the operation of ships in international traffic may be taxed in the ContractingState in which such operation is carried on; but the tax so charged shall not exceed 50 per cent of the tax otherwise imposed by the internal law of that State. PROVIDED that for the purpose of the calculation of the tax....
TaxTMI