Article 8 - Shipping and air transport - Slovenia

ARTICLE 8 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. 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 no such home harbour, in the Contracting State of which the operator of the ship is a resident. 3. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall mean the profits derived by an enterprise referred to in paragraph 1 from transportation by sea or air of passengers, livestock or goods. 4. Profits derived by an enterprise referred to in paragraph 1 shall also include profits from the use, maintenance or rental of containers used for the transport of goods or merchandise in international traffic. 5. For the purposes of this Article interest on funds connected with the operation of ships or aircraft in international traffic shall be regarded as profits derived from the operation of such ships or aircraft if they are incidental to the carrying on of such business, and the provisions of Article 11 shall not apply in relation to such interest. 6. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.