(1) Profits derived by a resident of a Contracting State from the operation of ships, boats, aircraft, railway and road vehicles in international traffic shall be taxable only in that Contracting State.
(2) For the purposes of this Article profits from the operation of ships, boats and aircraft in international traffic include:
- (a) income from the rental on a bareboat basis ships or aircraft; and
- (b) profits from [the] use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise;
where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships, boats or aircraft in international traffic.
(3) Where profits, in accordance with paragraph 1 of this Article, are derived by a resident of a Contracting State from the participation in a pool, a joint business or an international operating agency, the profits attributable to that resident shall be taxable only in the Contracting State of which he is a resident.