Article 8 - Shipping and air transport - South Africa

ARTICLE 8 SHIPPING AND AIR TRANSPORT 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State. 2. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall include : (a) profits derived from the rental on a bare boat basis of ships or aircraft used in international traffic, (b) profits derived from the use or rental of containers, if such profits are incidental to the profits to which the provisions of paragraph 1 apply. 3. 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 and the provisions of Article 11 shall not apply in relation to such interest. 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.