- 1
- Profits derived by a resident of a Contracting State from the operation of ships, boats or aircraft in international traffic shall be taxable only in that State.
- 2
- For the purposes of this Article, profits derived from the operation in international traffic of ships, boats and aircraft include:
-
- a)profits derived from the rental on a bareboat basis of ships, boats and aircraft if operated in international traffic; and
- b)profits derived 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 profits or profits from such use, maintenance or rental, as the case may be, are incidental to the profits derived from the operation of ships, boats and aircraft in international traffic.
- 3
- The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
