Taxation of international shipping and air transport profits: exclusive taxing rights with a limited tax reduction exception.

Profits from operation or rental of ships or aircraft in international traffic, and rental of incidental containers and related equipment, are taxable only in the Contracting State of the enterprise; this includes profits from participation in pools, joint businesses or international operating agencies. Interest on funds directly connected with such operations is treated as operational profits and Article 11 does not apply where those funds are incidental. Profits from operation between the ports of the other Contracting State and third countries may be taxed in that other State, subject to a tax reduction amounting to two-thirds of the tax imposed there.

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