ARTICLE 8
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) For the purposes of this Article, profits from the operation of ships or aircraft in international traffic include:
- (a) income from the lease of ships or aircraft; and
- (b) profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers).
Where such lease or such use, maintenance or rental, as the case, maybe, is incidental to the operation of ships or aircraft in international traffic.
(3) The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.
(4) For the purposes of this Article, interest on funds connected with the operation of ships or aircraft in international traffic earmarked for the purpose of payments of all kinds of wages and maintenance of ships or aircraft and their crew shall be regarded as income or profits derived from the operation of such ships or aircraft and the provisions of Article 11 shall not apply in relation to such interest.