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of <h1>International Shipping Profits Taxed Where Management Resides; Container Profits Taxed in Enterprise's State; Article 11 Excluded.</h1> Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State where the enterprise's effective management is located. If management is aboard a ship, it is deemed to be in the State of the ship's registration or the operator's residence. Profits from using, maintaining, or renting containers for international transport are taxable only in the enterprise's State. Interest directly linked to operating ships or aircraft is treated as operational profits, excluding Article 11 provisions. These rules also apply to profits from participation in pools, joint businesses, or international operating agencies.
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