ARTICLE 8
Shipping and Air Transport
(1) Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(2) The provisions of paragraph (1) shall apply mutatis mutandis to participation of an enterprise engaged in international shipping or air transport in a pool, a joint business or other international operating agency.
(3) If the place of effective management of a shipping enterprise is aboard a ship, it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident.