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HMRC internal manual

Double Taxation Relief Manual

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

(1) Profits derived from the operation of ships or aircraft in international traffic by an enterprise of a Contracting State shall be exempt from tax in the other Contracting State.
(2) The provisions of paragraph (1) of this Article shall likewise apply to the share in respect of participation in shipping or aircraft pools of any kind by such an enterprise engaged in shipping or air transport.
(3) Profits from voyages of ships or aircraft confined solely to places within a Contracting State may be taxed in that State.