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of <h1>Profits from ships or aircraft operations are taxed only in home State unless confined to the other State.</h1> Profits from the operation of ships or aircraft by a resident of one Contracting State are taxable only in that State. However, if these profits arise from operations confined to the other Contracting State, they may be taxed there. This applies to profits derived through participation in a pool service, joint transport operating organization, or international operating agency. Profits from the carriage of passengers, livestock, mail, goods, or merchandise within a single Contracting State are considered as confined to that State for taxation purposes.
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