ARTICLE 8
Ocean Shipping, Domestic Shipping and Air Transport
(1) Profits from the operation of ocean ships and aircraft in international transport can be taxed only in that Contracting State in which the place of effective management of the enterprise is located.
(2) Profits from the operation of ships used in internal shipping can be taxed only in that Contracting State in which the place of effective management of the enterprise is situated.
(3) For the purpose of this Article the term "profits from the operation of ocean ships and aircraft in international transport" also include income from:
- (a) the occasional chartering of empty ships and aircraft,
- (b) the income from the use or renting of containers (inclusive of trailers and associated equipment that serves in the transportation of containers),
provided that these activities belong to the operation of ships and aircraft in international transport.
(4) If the place of effective management of a shipping enterprise is aboard a ship, this office shall be deemed to be situated in that Contracting State in which the home harbour of the ship or boat is situated, or in the absence of a home harbour, in the Contracting State of which the operator of the ship or boat is a resident.
(5) The provisions of paragraph (1) of this Article shall apply to the profits arising from the participation in a pool, a joint venture or an international operating agency.