- 1
- Income and profits from the operation in international traffic of owned or chartered vessels shall be taxable only in the territory of the Contracting Party where the place of effective management of the enterprise which operates the vessel is situated.
- 2
- The provisions of paragraph 1 of this Article shall also apply to income and profits obtained by chartering out vessels fully equipped, manned and supplied, irrespective of the nationality of the charterer.
- 3
- The provisions of paragraph 1 and 2 shall also apply to income and profits from the participation in a pool, a joint business or an international operating agency.
- 4
- Gains from the alienation of vessels operated in international traffic or of movable property pertaining to the operation of such vessels shall be taxable only in the territory of the Contracting Party where the place of effective management of the enterprise which operates the vessel is situated.