ARTICLE 8
International Traffic
(1) Profits from the operation of seagoing vessels or aircraft in international traffic can only then be taxed in the Contracting State in which the business's location of effective management is located.
(2) For the purposes of this Article the term, "profits from the operation of sea vessels or aircraft in international Traffic" as well as profits from:
- (a) occasional leasing of sea vessels or aircraft and
- (b) Use or leasing of containers (including trailers and the related equipment, which serve the transport of containers)
if these activities include operation of sea vessels or aircraft in international traffic.
(3) If the location of effective management of a business of maritime navigation is located aboard a ship, then it is deemed located in the Contracting State, in which the home port of the ship is located or, if there is no home port, in the Contracting State in which the person is resident who operates the ship.
(4) Paragraph (1) also applies to profits from the participation in a pool, an operating cooperative or an international business office.