Article 25 – Non-Resident Person Operating Aircraft or Ships in International Transportation

Income derived by a Non-Resident Person from the operation of aircraft or ships in international transportation shall not be subject to Corporate Tax where all of the following conditions are met:

1. The Non-Resident Person is in the Business of any of the following:

1. 1. International  transport  of  passengers,  livestock,  mail,  parcels,  merchandise  or goods by air or by sea.
   2. Leasing or chartering aircrafts or ships used in international transportation.
   3. Leasing of equipment which are integral to the seaworthiness of ships or the airworthiness of aircrafts used in international transportation.

2. A Resident Person that performs any of the activities under Clause 1 of this Article would be exempt, or not be subject to tax that is of a similar character to Corporate Tax, under the applicable legislation of the country or territory in which the Non-Resident Person is resident.