1. Profits derived by a resident of a Contracting State from the operation of ships or  aircraft in international traffic shall be taxable only in that State.  

2. For the purpose of this Article, profits from the operation of ships or aircraft in  international traffic include:  

a) profits from the rental on a bare boat basis of ships or aircraft; and  

b) profits 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, where such rental or such use, maintenance or rental, as the case may be, is incidental to  the operation of ships or aircraft in international traffic.

3. The provisions of paragraph 1 shall also apply to profits from the participation in a  pool, a joint business or an international operating agency.