Taxation of international shipping and air transport profits confined to the enterprise's contracting state, including related leases and pool income.

Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State, including income from leasing ships or aircraft and from use, maintenance or rental of containers when incidental to such operation; this also covers participation in pools, joint businesses or international operating agencies. Interest on funds earmarked for wages and maintenance of ships, aircraft and crew is treated as operational income and excluded from the treaty's general interest taxation rule.

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