Sea and Air Transport
(1) Profits generated from the operation of ships, aircraft or vehicles in international transport shall be taxable only in the Contracting State.
(2) For the purposes of this Article, profits generated from the operation of ships, aircraft or vehicles in international transport shall include:
- (a) profits from the rental of ships aircraft or vehicles.
- (b) profits from the use, maintenance or rental of containers in international transport (including locomotives and any other equipment related to the transport of containers) where such activities are supplementary or incidental to the operation of ships and aircraft in international transport.
- (c) interest on funds directly resulting from the operations of ships, aircraft and air transport related to these operations.
(3) The provisions of paragraphs (1) and (2) of this Article shall also apply to profits obtained by a resident of a Contracting State from participating in a union, joint business or agency managed at an international level.