The main change relates to article 14 paragraph 4 of the tax treaty ("Income from employment"). Currently, in the tax treaty article 14 paragraph 4 indicates that income from employment on a ship or airplane exploited in international waters or a barge is taxed in the country of residence of the employee.
According to the amended protocol article 14 paragraph 4 of the tax treaty will indicate that income from employment on a ship or airplane that is exploited internationally or a barge will be taxed in the country where the place of effective management of the company exploiting the ship, airplane or barge is located.