Shipping and Air Transport
(1) Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2) If the place of effective management of a shipping enterprise is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State of which the operator of the ship or boat 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) Profits that mentioned in this Article include all profits derived from the operation of ships and aircraft in international traffic, including profits from the rental of ships or aircraft on a full (time, voyage or bareboat) basis and profits from the rental of containers and related equipment which is supplementary or incidental to the operation of ships and aircraft in international traffic.