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<h1>Taxation of international shipping profits confined to the enterprise's contracting state, limiting other State taxation.</h1> Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's Contracting State; a shipboard place of effective management is deemed in the State of the home harbour or of the operator's residence. Container use, maintenance or rental incidental to international operation is taxable only in the resident State unless used solely in the other State. Interest integral to ship or aircraft operations is treated as operating profits and Article 11 does not apply. The exclusive taxing rule and deemed management location also cover participation in pools, joint businesses or international operating agencies.
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