(1) Profits from the operation of ships or aircraft in
international traffic shall be taxable only in the Contracting
State in which the place of effective management of the enterprise
is situated.
(2) If the place of effective management of a shipping
enterprise is aboard a ship then it shall be deemed to be situated
in the Contracting State in which the home harbour of the ship is
situated, or, if there is no such home harbour, in the State of
which the operator of the ship is a resident.
(3) Where profits within paragraph (1) of this Article are
derived by an enterprise from participation in a pool, a joint
business or an international operating agency, the profits
attributable to that enterprise shall be taxable only in the
Contracting State in which the place of effective management of
that enterprise is situated. For the purposes of this paragraph the
expression `a pool, a joint business or an international operating
agency` shall not include a person, as defined in Article 3 of this
Convention.
(4) With respect to profits derived by the Danish, Norwegian
and Swedish air transport consortium, known as the Scandinavian
Airlines System (SAS), the provisions of paragraphs (1) and (3) of
this Article shall only apply to such part of the profits as
corresponds to the shareholding in the consortium held by AB
Aerotransport (ABA), the Swedish partner of Scandinavian Airlines
System (SAS).
