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ARTICLE 8
Shipping and Air Transport
(1) Notwithstanding the provisions of Article 7, profits derived by a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2) The provisions of paragraph (1) of this Article shall also apply to profits referred to in this Article derived by a resident of a Contracting State from his participation in a pool, a joint business or an international operating agency.
(3) In this Article:
- (a) the term "profits" includes:
- (i) profits, net profits, gross receipts and revenues derived directly from the operation of ships or aircraft in international traffic;
- (ii) interest on sums generated directly from the operation of ships or aircraft in international traffic which is incidental to such operation;
- (iii) income from the sale of tickets on behalf of an aircraft enterprise, and
- (iv) income from selling of engineering services to a third party and any other income arising from other technical services which are incidental to the operation of an aircraft enterprise;
- (b) the term "operation of ships or aircraft" includes:
- (i) the charter or rent of ships or aircraft;
- (ii) the rent of containers and related equipment, and
- (iii) the alienation of ships or aircraft, containers and related equipment by that person,
- provided that such charter, rent or alienation is incidental to the operation by that person of ships or aircraft in international traffic.