Artikel 10

1. Income and profits from the participation in the international air transportation covered by this Agreement shall be taxable only in the State in which the place of effective management of the enterprise is situated.
2. Gains from the alienation of aircraft operated in international traffic shall be taxable only in the State in which the place of effective management of the enterprise is situated.
3. Capital represented by aircraft operated in international traffic and by movable property pertaining to the operation of such aircraft shall be taxable only in the State in which the place of effective management of the enterprise is situated.
4. The provisions of paragraph 1 of this Article shall also apply to income and profits from the participation in a pool, a joint business or an international operating agency.
5. If an agreement between the Contracting Parties on avoidance of double taxation and the prevention of fiscal evasion on income and on capital envisages procedures different from those referred to in paragraphs 1–4 of this Article, the provisions of the agreement on avoidance of double taxation on income or capital shall be applicable.