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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) 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 are incidental to the operation of ships or aircraft in international traffic.
(3) Paragraph (1) shall also apply to the share of the profits from the operation of ships or aircraft through participation in a pool, a joint business or an international operating agency.