Shipping and Air Transport

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....anagement of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbor of the ship is situated, or, if there is no such home harbor, in the Contracting State of which the operator of the ship is a resident. 3. The term "operation of ships or aircraft" means business of transportation by sea or by air of passengers, m....

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....including trailers and other equipment for the transport of containers) used for the transport of goods or merchandise in international traffic shall be taxable only in that Contracting State unless the containers are used solely within the other contracting State. 6. For the purposes of this Article interest on investments directly connected with the operation of ships or aircraft in internation....