ARTICLE 8
Sea and Air Traffic
(1) Profits derived 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) Where the place of effective management of a shipping enterprise is aboard a ship, then such enterprise shall be deemed to be situated in the Contracting State in which the home harbour of this ship is situated. If there is no such home harbour, then the place of effective management of the enterprise shall be deemed to be situated in the Contracting State of which the operator of the ship is a resident.
(3) The provisions of paragraph (1) of this Article shall also apply to profits arising out of the participation in a pool, a joint business, or an international operating agency.