Article 9 - Shipping - Italy

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. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency engaged in the operation of ships. 3. For the purpose of this Article, interest on funds connected with the operation of ships in international traffic shall be regarded as income from the operation of such ships and the provisions of Article 12 shall not apply in relation to such interest. 4. For the purpose of paragraph 1 of this Article, income from the operation of ships in international traffic shall include :- (a) profits derived from the rental on a full or bareboat basis of ships if such rental profits are incidental to the operation of ships in international traffic, and (b) profits derived from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) in connection with the transport of goods or merchandise in international traffic. 5. Paragraph 1 shall not apply to profits arising as a result of coastal traffic.