AGREEMENT BETWEEN

INTERNATIONAL 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 Contracting State. 2.  For purposes of this Article, profits from the international operation of ships or aircraft include, but are not limited to: a)  profits from the rental of ships or aircraft on a full (time or voyage) basis operated in international traffic; b)  profits from the rental on a bareboat basis of ships or aircraft if the rental income is incidental to profits from the operation of ships or aircraft in international traffic; and c)  profits from the rental on a bareboat basis of ships or aircraft if such ships or aircraft are operated in international traffic by the lessee. Profits derived by an enterprise referred to in paragraph 1 of this Article from the inland transport of property or passengers within either Contracting State shall be treated as prof- its from the operation of ships or aircraft in international traffic if such transport is undertaken as part of international traffic. 3.  The provisions of paragraph 1 of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency.