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) For the purposes of this Article, the terms "profits from the operation of ships or aircraft in international traffic" shall include profits from
- (a) the occasional rental of ships or aircraft on a bare-boat basis and
- (b) the use or rental of containers (including trailers and ancillary equipment used for transporting the containers),
if these activities pertain to the operation of ships or aircraft in international traffic.
(3) If the place of effective management of a shipping enterprise is aboard a ship, then 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.
(4) The provisions of paragraph (1) shall also apply to profits from the participation in a pool, a joint business or an international operating agency.