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of <h1>Profits from international ship or aircraft operations are taxed only in the enterprise's resident State, exempting Article 11.</h1> Profits from the operation of ships or aircraft in international traffic by an enterprise of a Contracting State are taxable only in that State. Similarly, profits from the use, maintenance, or rental of containers by a resident transportation enterprise are taxable solely in the resident State, unless used solely within the other State. Interest on investments related to such operations is treated as operational profits, exempting them from Article 11. These rules extend to profits from participation in pools, joint businesses, or international agencies, including the Scandinavian Airlines System, with profits for SAS Norge AS taxed according to its share.
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