Shipping and Air Transport
(1) Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
(2) However, if such operation in international traffic is carried on by an enterprise of only one of the Contracting States, paragraph (1) will not be applicable. In such a case, the tax charged shall not exceed one per cent of the earnings of the enterprise derived from the other Contracting State.
For the purpose of this paragraph, "earnings" means total income arising from the carriage of passenger, mails, livestock or goods loaded or shipped in the other State, less refunds and payment of wages and salaries of ground staff with respect to such operations in international traffic.
(3) For the purposes of this Article, profits derived by an enterprise of a Contracting State from the operation of the ships or aircraft in international traffic shall include inter all profits derived from the use or rental of containers, if such profits are incidental to the profits to which the provisions of paragraph (1) apply.
(4) The provisions of paragraph (1) of this Article shall also apply to profits from participation in a pool, a joint business or an international operating agency.