Income from international transport: generally taxable only in the enterprise's Contracting State; limited tax by other State with reduction.

Income from the operation or rental of ships or aircraft in international traffic, and rental of containers and related equipment incidental thereto, is taxable only in the Contracting State of the enterprise. The rule applies to participation in pools, joint businesses and international operating agencies; interest directly connected with such operations is treated as operating income and excluded from the separate interest provision. An exception allows the other Contracting State to tax carriage between its ports and third country ports, subject to a statutory reduction of that other State's tax.

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