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ARTICLE 8
Shipping and Air Transport
(1) Notwithstanding the provision of paragraph (1) of Article 7, profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic in the other Contracting State shall be taxable only in the first-mentioned Contracting State.
(2) For the purpose of this Article, profits from the operation of ships or aircraft in international traffic shall include:
- (a) profits derived occasionally from the rental on a bareboat basis of ships or aircraft used in international traffic;
- (b) profits derived from the use or rental of containers, if such profits are supplementary or incidental to the profits to which the provisions of paragraph (1) apply;
- (c) interest on funds directly connected with such operation.
(3) The provisions of paragraphs (1) and (2) shall also apply to profits from the participation in a pool, a joint business or an international operating agency.