- 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 State.
- 2
- For the purposes of this Article:
-
- a)the term “profits” includes:
- (i)gross revenues derived directly from the operation of ships or aircraft in international traffic, and
- (ii)interest over the amounts derived directly from the operation of ships or aircraft in international traffic, only if such interest is incidental to the operation.
- b)the expression “operation of ships or aircraft” by an enterprise, also includes:
- (i)the charter or rental on a bareboat basis of ships and aircraft;
- (ii)the rental of containers and related equipment, if that charter or rental is incidental to the operation by the enterprise of ships or aircraft in international traffic.
- 3
- The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
