Shipping and Air Transport
(1) Profits from the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State in which the place of effective management of the enterprise is situated.
(2) If the effective management of a shipping enterprise is aboard a ship then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or if there is no such home harbour, in the Contracting State of which the operator of the ships is a resident.
(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, profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic include profits from the use or rental of containers, if such profits are incidental to the profits to which the provisions of paragraph (1) apply.