Profits from ships and aircraft: residence-based taxation with an exception where operations occur solely within the other State.

Profits from the operation of ships or aircraft by a resident are taxable only in the State of residence, subject to a territorial exception permitting the other State to tax profits where operations are confined solely to that other State; this allocation also covers a resident's share of profits from pool services, joint transport organisations or international operating agencies, and carriage originating and discharging within one Contracting State is treated as confined to that State.

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