- 1
- Profits from the operation of ships or 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
- 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.
- 3
- For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
-
- a)profits from the rental on a bareboat basis of ships and aircraft;
- b)profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise;where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic; and
- c)profits from the sale of tickets for the service of transportation by sea or air on behalf of other enterprises.
- 4
- For the purposes of this Article, interest or funds directly connected with the operation of ships or aircraft in international traffic shall be regarded as profits derived from the operation of such ships or aircraft, and the provisions of Article 11 shall not apply to such interest.
- 5
- The provisions of paragraph 1, 3 and 4 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
