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of <h1>International Shipping and Airline Profits Taxable Only in Resident State, Includes Containers and Joint Ventures.</h1> Profits earned by an enterprise of a Contracting State from operating ships or aircraft in international traffic are taxable only in that State. This includes profits from transporting passengers, goods, mail, or livestock by sea or air. Profits from using or renting containers for international transport are also taxable only in the enterprise's resident State, unless used solely within the other State. Interest directly linked to the operation of ships or aircraft is considered part of these profits, excluding the application of Article 11. These provisions also cover profits from participation in pools, joint businesses, or international operating agencies.
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