租税条約 第8条（国際運送事業）
令和7年10月31日|p.24
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ARTICLE 8
INTERNATIONAL SHIPPING AND AIR TRANSPORT
1. Profits of an enterprise of a Contracting State from the operation of ships or
aircraft in international traffic shall be taxable only in that Contracting State.
2. Notwithstanding the provisions of Article 2, an enterprise of a Contracting State
shall be exempt in respect of its carrying on the operation of ships or aircraft in
international traffic from, in the case of an enterprise of Turkmenistan, the enterprise tax
of Japan and, in the case of an enterprise of Japan, any tax similar to the enterprise tax of
Japan which is imposed after the date of signature of this Convention in Turkmenistan.
3. The provisions of paragraphs1 and2 shall also apply to profits from the
participation in a pool, a joint business or an international operating agency