- 1
- Profits from the operation of aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
- 2
- Profits arising in a Contracting State and derived from the operation of ships in international traffic by an enterprise having its place of effective management in the other Contracting State may be taxed in the first-mentioned State but the rate of tax chargeable in that State shall be reduced to fifty per cent thereof and shall in no case exceed 4 per cent.
- 3
- If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident.
- 4
- The provisions of paragraphs 1 and 2 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.