(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
(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.