(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 Contracting
State of which the operator of the ship is a resident.
(3) The provisions of this Article shall also apply to
profits derived from participation in a pool, a joint business or
an international operating agency.
