Part Article 8
Profits of an enterprise of a Contracting State from the operation of ships, aircraft, road vehicles or railways in international traffic shall be taxable only in that State.
For the purposes of this Article, profits from the operation of ships, aircraft, road vehicles or railways in international traffic include:
income from the rental on a bareboat basis of ships, aircraft, or railway or road vehicles; and
profits from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise;
where such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships, aircraft, road vehicles or railways in international traffic.
The provisions of paragraphs (1) and (2) of this Article shall also apply to profits from the participation in a pool, a joint business or an international operating agency, but only to so much of the profits so derived as is attributable to the participant in proportion to its share in the joint operation.