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ARTICLE 8

U.S. Income Tax Treaty — austria tax treaty documents: austria.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Shipping and Air Transport

  1. Profits of an enterprise of a Contracting State from the operation in international traffic of ships or aircraft shall be taxable only in that State.

  2. For purposes of this Article, profits from the operation in international traffic of ships or aircraft include profits derived from the rental on a full or bareboat basis of ships or aircraft if operated in international traffic by the lessee or if such rental profits are incidental to other profits described in paragraph 1.

  3. Profits of an enterprise of a Contracting State from the use, rental or maintenance of containers (including trailers, barges, and related equipment for the transport of containers) used in international traffic shall be taxable only in that State.

  4. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.

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▸Contents — U.S. Income Tax Treaty — austria tax treaty documents: austria.pdf

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