Taxation of shipping and air transport: profits taxable only in the state of effective management, including related interest. Profits from operating ships or aircraft in international traffic are taxable only in the Contracting State of the place of effective management, deemed for ships managed aboard to be the State of the home harbour or the operator's State of residence; this rule also covers participation in pools, joint businesses and international operating agencies. Interest connected with such operations is treated as operational profits and excluded from Article 11. 'Operation of ships or aircraft' includes transportation of persons, mail, livestock or goods, ticket sales on behalf of others, incidental leases and other activities directly connected with transportation.