- 1
- Profits from the operation of ships or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
- 2
- For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall include:
-
- a)profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic, and
- b)profits derived from the use, rental or lease of containers,
- if such profits are incidental to the profits to which the provisions of paragraph 1 apply.
- 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.