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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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DT: Ivory Coast: double taxation agreement, Article 8: Shipping and air transport

  1. Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

  2. If the place of effective management of a shipping enterprise is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship or boat is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship or boat is a resident.

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

With respect to profits derived by the air transport company Air-Afrique the provisions of this paragraph and of paragraph (1) of this Article shall only apply to the share of profits attributed to the Ivory Coast.