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    <description>Profits from operation or rental of ships or aircraft in international traffic and rental of containers incidental to that operation are taxable only in the enterprise&#039;s Contracting State; this includes participation in pools, joint businesses or international operating agencies. Interest directly connected to such operations is treated as operational profits and Article 11 does not apply if incidental. Profits from voyages between the ports of the other Contracting State and third countries may be taxed by that other State but such tax must be reduced by two-thirds.</description>
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      <description>Profits from operation or rental of ships or aircraft in international traffic and rental of containers incidental to that operation are taxable only in the enterprise&#039;s Contracting State; this includes participation in pools, joint businesses or international operating agencies. Interest directly connected to such operations is treated as operational profits and Article 11 does not apply if incidental. Profits from voyages between the ports of the other Contracting State and third countries may be taxed by that other State but such tax must be reduced by two-thirds.</description>
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