Taxation of shipping and air transport profits: resident-state taxation with a source-state exception for wholly domestic operations.

Profits from operating ships or aircraft, including related interest, are taxable only in the resident Contracting State, except where operations are confined solely to places in the other Contracting State, in which case that other State may tax them; this exclusive taxation rule and the exception apply to shares of profits from pool services, joint transport operating organisations and international operating agencies, and carriage entirely within one Contracting State is treated as confined operations taxable in that State.

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