Shipping and Air Transport
(1) Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2) The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency engaged in the operation of ships or aircraft.
(3) Interest on funds connected with the operation of ships or aircraft in international traffic shall be regarded as profits derived from the operation of such ships or aircraft, and the provisions of Article 11 shall not apply in relation to such interest.
(4) For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall mean profits derived from the transportation by sea or air of passengers, mail, livestock or goods carried on by the owners or lessees or charterers of the ships or aircraft, including profits from:
- (a) the sale of tickets for such transportation on behalf of other enterprises;
- (b) the incidental lease of ships or aircraft used in such transportation;
- (c) the use, maintenance or rental or containers (including trailers and related equipment for the transport of containers) in connection with such transportation; and
- (d) any other activity directly connected with such transportation.