- 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 derived from the operation in international traffic of ships and aircraft include:
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- a)profits derived from the rental on a bareboat basis of ships and aircraft if operated in international traffic if such rental profits are an occasional source of income to the profits described in paragraph 1;
- b)profits derived from the use, maintenance or rental of containers (including trailers, barges and related equipment for the transport of containers) used for the transport of goods and merchandise in international traffic if such profits are an occasional source of income to the profits described in paragraph 1.
- 4
- The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.