International transport profits taxable only in the enterprise's home state, including container income and joint operating arrangements.

Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic are taxable only in that State. The same treatment applies to profits from participation in a pool, a joint business, or an international operating agency. Profits from the use, maintenance, or rental of containers used for transport of goods are also taxable only in that State when incidental to such international transport income, except where the containers are used solely within the other Contracting State.

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