ARTICLE 8
Shipping and Air Transport
(1) Profits from the operation of ships or aircraft in international traffic carried on by an enterprise of a Contracting State shall be taxable only in that State.
(2) For the purposes of this Article, the terms "profits from the operation of ships or aircraft in international traffic" shall include profits derived from
- (a) the rental of a ship or aircraft on a bare-boat charter basis; and
- (b) the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods and merchandise,
where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic.
(3) Interest on investments directly connected with the operation of aircraft and ships in international traffic shall also be regarded as profits derived from the operation of such aircraft and ships if they are integral to the carrying on of such business.
(4) The provisions of paragraph 1 shall also apply to profits derived from the participation in a pool, a joint business or an international operating agency.