Artikel 10

1. Profits or income from the operation of aircraft in international traffic derived by a Designated Airline of a Party, including participation in inter-airline commercial arrangements or joint business ventures, shall be exempt from any tax on profits or income imposed by the other Party.
2. Capital and assets of a Designated Airline of a Party pertaining to the operation of aircraft in international traffic shall be exempt from any tax on capital and assets imposed by the other Party.
3. Gains from the alienation of aircraft operated in international traffic and movable property pertaining to the operation of such aircraft derived by a Designated Airline of a Party shall be exempt from any tax on gains imposed by the other Party.
4. For the purposes of this Article:
a) the term “profits or income” includes gross receipts and revenues derived directly from the operation of aircraft in international traffic, including: i) the charter or rental of aircraft;
ii) the sale of air transportation, either for the Airline itself or for any other Airline; and
iii) interest on sums generated directly from the operation of aircraft in international traffic provided that such interest is incidental to the operation;
i) the charter or rental of aircraft;
ii) the sale of air transportation, either for the Airline itself or for any other Airline; and
iii) interest on sums generated directly from the operation of aircraft in international traffic provided that such interest is incidental to the operation;
b) the term “international traffic” means the transportation of persons and/or cargo, including mail, except where such transportation is principally between points in the Territory of a Party.
5. This Article shall not have effect when an agreement for the avoidance of double taxation with respect to taxes on income is in effect between the Parties.