Artikel 8A

1. 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 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 taxes of every kind and description 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 on gains only in the area of that Contracting Party.
4. For the purposes of this Article:
a) the term ‘income or profits derived from the operation of aircraft in international traffic’ shall include 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 of for any other airline;
(iii) interest on funds directly connected with the operation of aircraft in international traffic;
(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 of for any other airline;
(iii) interest on funds directly connected with the operation of aircraft in international traffic;
b) the term ‘international traffic’ means any carriage by an aircraft except when such carriage is solely between places in the area of the other Contracting Party;
c) the term ‘airline of one Contracting Party’ means in the case of Hong Kong, an airline incorporated and having its principal place of business in Hong Kong and in the case of the Kingdom of the Netherlands, an airline substantially owned and effectively controlled by the Government of the Kingdom of the Netherlands or its nationals.
5. This Article shall not have effect as long as an Agreement for the avoidance of double taxation with respect to taxes on income or profits providing for similar exemptions shall be in force between the Contracting Parties.