Shipping and Aircraft Operations
(1) Profits from ship or aircraft operations derived by a resident of a Contracting State shall be taxable only in that State.
(2) Notwithstanding the provisions of paragraph (1), such profits may be taxed in the other Contracting State where they are profits from ship or aircraft operations confined solely to places in that other State.
(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.
(4) For the purposes of this Article, profits derived from the carriage by ships or aircraft of passengers, livestock, mail, goods or merchandise which are shipped in a Contracting State for discharge at a place in that State shall be treated as profits from ship or aircraft operations confined solely to places in that State.