Article 8 PROFITS FROM INTERNATIONAL TRANSPORT

1. Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic and the rental on a full or bareboat basis of ships or aircraft, or of containers and related equipment, which in either case is incidental to the operation of ships or aircraft in international traffic shall be taxable only in that Contracting State.

2. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.