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Chapter: | 112Q
 | Title: | SPECIFICATION OF ARRANGEMENTS (GOVERNMENT OF THE FEDERAL REPUBLIC OF GERMANY CONCERNING AIR SERVICES) (DOUBLE TAXATION) ORDER | Gazette Number: | L.N. 486 of 1997 |
| Schedule: | Heading: | SCHEDULE | Version Date: | 24/10/1997 |
[section 2]
ARTICLE 8A
of the
AGREEMENT BETWEEN THE GOVERNMENT OF HONG KONG AND
THE GOVERNMENT OF THE FEDERAL REPUBLIC OF GERMANY
CONCERNING AIR SERVICES
of the
AGREEMENT BETWEEN THE GOVERNMENT OF HONG KONG AND
THE GOVERNMENT OF THE FEDERAL REPUBLIC OF GERMANY
CONCERNING AIR SERVICES
Made in Hong Kong on the 5th day of May 1995, as amended by the Agreed Amendment to the Agreement made on 8 May 1997.
"ARTICLE 8A
Avoidance of Double Taxation
(1) Revenues, gross receipts, income or profits derived from the operation of aircraft in international traffic by an airline of one Contracting Party, including participation in a pool service, a joint air transport operation or an international operating agency, which are subject to tax in the area of that Contracting Party shall be exempt from income tax, profits tax and all other taxes on revenues, receipts, income or profits imposed in the area of the other Contracting Party.
(2) Capital and assets of an airline of one Contracting Party relating to the operation of aircraft in international traffic shall be exempt from all taxes on capital and assets imposed in the area of the other Contracting Party.
(3) Gains from the alienation of aircraft operated in international traffic and movable property pertaining to the operation of such aircraft which are received by an airline of one Contracting Party shall be subject to tax only in the area of that Contracting Party.
(4) For the purpose of this Article:
- (a) the term "revenues, gross receipts, income or profits derived from the operation of aircraft in international traffic" shall include revenues, gross receipts, income or profits from the operation of aircraft for the carriage of persons, livestock, goods, mail or merchandise including:
- (i) the lease of aircraft on a charter basis;
(ii) the sale of tickets for and the provision of services connected with such carriage, either for the airline itself or for any other airline;
(iii) interest on funds directly connected with the operation of aircraft in international traffic;
(c) the term "airline of one Contracting Party" means an airline incorporated and having its principal place of business in the area of that Contracting Party.