P.O. Box 6898

SHIPPING AND AIR TRANSPORT 1. Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. 2. The term "profits derived from the international operation of ships or aircraft" includes: (i) profits derived from the rental on a full (time or voyage) basis of ships or aircraft used in international transport; (ii) profits derived from the rental on a bareboat basis of a ship or aircraft used in international transport; (iii) profits derived from the use or rental of containers and related equipment used in international transport that is incidental to income from the international operation of ships or aircraft. 3. If the place of 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 ship is a resident. 4. 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.