Shipping, Air and Motor Transport
(1) Profits derived by an enterprise of a Contracting State derived from operation of aircraft or motor vehicles 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.
(3) For the purposes of this Article, interest on funds connected with the operation of aircraft or motor vehicles in international traffic shall be regarded as profits derived from the operation of such aircraft or motor vehicles, and the provisions of Article 11 shall not apply in relation to such interest.
(4) The term "operation of aircraft" shall mean business of transportation by air of passengers, mail, livestock or goods carried on by the owners or lessees or charterers of aircraft, including the sale of tickets for such transportation on behalf of other enterprise, the incidental lease of aircraft and any other activity directly connected with such transportation.
(5) Profits derived by an enterprise from operation of ships, shall be taxable in the Contracting States in accordance with their domestic laws.