ARTICLE 6
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 actual management of the enterprise is situated.
(2) Profits from the operation of boats engaged in inland waterways transport shall be taxable only in the Contracting State in which the place of actual management of the enterprise is situated.
(3) If the place of actual management of a shipping or inland waterways transport enterprise is on board a ship or boat, it shall be deemed to be situated in the Contracting State in which the home port of the ship or boat is situated. If the home port is not situated in either of the Contracting States, the place of actual management shall be deemed to be situated in the Contracting State of which the operator of the ship or boat is a resident.
(4) Paragraphs (1) and (2) shall apply mutatis mutandis to business tax levied on a base other than the commercial profit.