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of <h1>Article 9: Tax on International Shipping Income Limited to Enterprise's Home State; Includes Bareboat Rentals and Container Use.</h1> Article 9 of the Double Tax Avoidance Agreement addresses taxation related to shipping. It specifies that income from the operation of ships in international traffic by an enterprise of a Contracting State is taxable only in that State. This does not apply to income from domestic journeys within a Contracting State. Income from bareboat rental of ships is included if incidental to the primary shipping income. The provisions extend to income from the use, maintenance, or rental of containers and participation in pools or joint ventures. Gains from the sale of ships or containers are taxed only in the originating State under certain conditions.
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