ARTICLE 8
Shipping and Air Transport
(1) Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2) For the purposes of this Article, 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. It also includes profits derived from the rental of ships or aircraft on a bareboat basis by an enterprise engaged in the operation of ships or aircraft in international traffic, if such rental activities are incidental to the activities described in paragraph (1).
(3) Profits of an enterprise of a Contracting State from the use, maintenance or rental of containers (including trailer barges and related equipment for the transport of containers) used in international traffic shall be taxable only in that State.
(4) The provisions of paragraph (1) shall also apply to profits derived from the participation in a pool, a joint business or an international operating agency.