SECTION 4

Air transport 1. Profits of an enterprise of a Contracting State from the operation of 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. Capital represented by aircraft operated in international traffic by an enterprise of a - 5 ­ Contracting State as well as movable property pertaining to the operation of such aircraft shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. 3. Gains from the alienation of aircraft operated in international traffic by an enterprise of a Contracting State or movable property pertaining to the operation of such aircraft, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. 4. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. 5. For the purposes of this Article, the term “profits of an enterprise of a Contracting State from the operation of aircraft in international traffic” shall mean: a) income and gross proceeds from the operation of aircraft for the transportation of persons, livestock, goods, mail or merchandise; b) profits from the lease on charter of fully equipped or bare aircrafts; c) profits from the use or rental of containers (including trailers and ancillary equipment used for transporting the containers).Charges for the late return of containers shall not, however, be deemed to be profits from international traffic; d) interest from assets directly linked to the operation.