Shipping and Air Transport
(1) Income and profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2) The provision of paragraph 1 shall also apply to the share of income and profits from the operation of ships or aircraft derived by a resident of a Contracting State through participation in a pool, a joint business or an international operating agency.
(3) In this Article:
- (a) the term "profits" includes:
- (i) interest derived from the deposits with any bank of any income or profit derived from the operation of ships or aircraft between the Contracting State.
- (b) the term "operation of ships or aircraft" in international traffic by a person, includes:
- (i) the charter or rental of ships or aircraft,
- (ii) the rental of containers and related equipment, and
- (iii) the alienation of ships, aircraft, containers and related equipment,
- by that person provided that such charter, rental or alienation is incidental to the operation by that person of ships or aircraft in international traffic.