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<h1>Aircraft Operation Profits Taxed Only Where Enterprise's Effective Management is Located; Includes Interest, Excludes Article 12.</h1> Profits from the operation of aircraft in international traffic by an enterprise of a Contracting State are taxable only in the state where the enterprise's effective management is located. This applies to profits from participation in a pool, joint business, or international operating agency. Interest on funds related to aircraft operations is considered part of these profits, excluding the application of article 12. 'Operation of aircraft' includes air transportation of people, luggage, livestock, goods, or mail, ticket sales, incidental aircraft leasing, and related activities.