International Ship and Aircraft Profits Taxed Where Management Resides, Includes Pools and Joint Businesses.

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 a shipping enterprise's management is aboard a ship, it is considered situated in the Contracting State of the ship's home harbor or the operator's residence. These rules also apply to profits from participation in pools, joint businesses, or international operating agencies. "Operation of ships or aircraft" includes the transportation of persons, mail, livestock, or goods by owners, lessees, or charterers, and ticket sales for such transportation on behalf of other enterprises.

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