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of <h1>International Traffic Profits Taxable Only in Home State, Exceptions for Local Voyages and Article 11 Exclusion Applied</h1> Profits earned by an enterprise from operating ships or aircraft in international traffic are taxable only in the enterprise's home state. However, if the primary purpose of a voyage is to transport passengers or goods between places in the other contracting state, those profits may be taxed there. Profits include those from ticket sales, related activities, and incidental rentals. Profits from using containers in international traffic are also taxable only in the home state. These rules extend to profits from participation in pools or joint ventures. Interest related to such operations is considered part of these profits, excluding Article 11's application. This article excludes drilling rigs or vessels primarily used for non-transportation activities.
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