Shipping, Air Transport and Containers
(1) Profits of a resident of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State.
(2) For the purposes of this Article and notwithstanding the provisions of Article 12, the term "profits from the operation of ships or aircraft in international traffic" includes profits derived from the rental of ships or aircraft on a full (time or voyage) basis and also includes profits from the rental of ships or aircraft on a bareboat basis, if such rental activities carried on by a resident of a Contracting State are incidental to the activity mentioned in paragraph (1).
(3) Notwithstanding the provisions of Article 12, profits of a resident of a Contracting State from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise shall be taxable only in that Contracting State, except insofar as those containers or trailers and related equipment are used for transport solely between places within the other Contracting State.
(4) The provisions of paragraphs (1) and (3) shall also apply to profits derived from the participation in a pool, a joint business or in an international operating agency.
(5) The provisions of paragraphs (1), (3) and (4) shall apply to profits derived by the joint Norwegian, Danish and Swedish air transport consortium Scandinavian Airlines System (SAS), but only insofar as profits derived by SAS Norge ASA, the Norwegian partner of the Scandinavian Airlines System (SAS), are in proportion to its share in that organisation.