Taxation of shipping and air transport profits limited to the state of effective management; interest treated as transport income. Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of the enterprise's place of effective management. If that place is aboard a ship, it is deemed to be in the State of the ship's home harbour or, lacking a home harbour, the State of the operator's residence. Interest connected with such operations is treated as transport profits and Article 11 does not apply. The rule also extends to profits from participation in pools, joint businesses or international operating agencies.