Singapore (tax/treaty)

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. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall include: a. profits derived from the rental on a full (time or voyage) basis of ships or aircraft used in international traffic; b. profits derived from the rental on a bareboat basis of ships or aircraft used in international traffic that is incidental to income from the operation of ships or aircraft in international traffic; c. profits derived from the use, maintenance or rental of containers and related equipment used in international traffic that is incidental to income from the operation of ships or aircraft in international traffic. 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.