Article 9 - Shipping - Great Britain and Northern Ireland (Old - Effective upto 10-02-1994)

ARTICLE 9 Shipping 1. Income of an enterprise of a Contracting State from the operation of ships in international traffic shall be taxable only in that State. 2. Notwithstanding the provisions of paragraph 1 of this Article such income may be taxed in the other Contracting State from which it is derived provided that: (a) the income is in respect of any one or more of the first ten fiscal years for which this Convention has effect; (b) the tax chargeable on that income shall be 50 per cent. of the tax which would have been chargeable in the absence of this Convention in respect of the income for the first five fiscal years for which this Convention has effect and 25 per cent. of such tax for the next following five years. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply to income from journeys between places which are situated in a Contracting State. 4. For the purposes of this Article, income from the operation of ships includes income derived from the rental on a bareboat basis of ships if such rental income is incidental to the income described in paragraph 1 of this Article. 5. Notwithstanding the provisions of Article 7 (Business profits), the provisions of paragraphs 1 and 2 and 3 of this Article shall likewise apply to income of an enterprise of a Contracting State from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise. 6. The provisions of this Article shall apply also to income derived from participation in a pool, a joint business or an international operating agency. 7. Gains derived by an enterprise of a Contracting State from the alienation of ships or containers owned and operated by the enterprise shall be taxed only in that State if either the income from the operation of the alienated ships or containers was taxed only in that State, or the ships or containers are situated outside the other Contracting State at the time of the alienation.