Pakistan (tax/treaty)

SHIPPING AND AIR TRANSPORT 1. Profits from the operation of ships oraircraft 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 or of an inland waterways transport 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 paragraphs 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. 4. Nothing contained in this Article shall affect the rights and obligations of the Contracting States under the agreement between the Kingdom of Saudi Arabia and the Islamic Republic of Pakistan for the avoidance of double taxation of income of air transport enterprises signed in 10/11/1401 [H] corresponding to 18.11.1980.