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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. If that State according to its legislation cannot tax the whole of the income, the income shall be taxable only in the Contracting State of which the enterprise is a resident.
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 not such home harbour, in the Contracting State of which the operator of the ship is a resident.
3. With respect to profits derived by the air transport consortium Scandinavian Airlines System (SAS) the provisions of paragraph (1) shall apply only to such part of the profits as corresponds to the participation held in that consortium by AB Aerotransport (ABA), the Swedish partner of Scandinavian Airlines System.
4. For the purposes of this Article, profits derived from the operation in international traffic of ships and aircraft include profits from the rental on a bareboat basis of ships and aircraft operated in international traffic if such rental profits are incidental to the profits described in paragraph (1).
5. The provisions of paragraph (1) shall also apply to profits from the participation in a pool, a joint business or an international operating agency.