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of <h1>Profits from international ship or aircraft operations are taxable where management is based, including interest.</h1> Profits from the operation of ships or aircraft in international traffic are taxable only in the Contracting State where the enterprise's effective management is located. If the management is on a ship, it is considered to be in the State of the ship's home harbour or the operator's residence. These provisions also apply to profits from participation in pools, joint businesses, or international agencies. Interest related to such operations is treated as operational profits, excluding Article 11's application. 'Operation of ships or aircraft' includes transportation of people, mail, livestock, goods, ticket sales, incidental leasing, and related activities.
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