Shipping income allocation: exclusive residence-state taxation with limited transitional source-state taxing rights. Shipping income of an enterprise from operation in international traffic is taxable only in the State of residence, subject to a limited transitional allowance for source-State taxation in initial fiscal years under reduced rates. Exclusions apply to voyages within a Contracting State. Bareboat rentals incidental to ship operation, container use or rental, pooling and joint operating arrangements fall within the Article; gains on alienation are taxable only in the residence State if prior operations were taxed solely there or the assets are situated outside the other State at alienation.