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Article 8 - INTERNATIONAL TRAFFIC - RomaniaExtract ARTICLE 8 INTERNATIONAL TRAFFIC 1. Profits from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. 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 place of registration of the ship is situated or, if there is no such place of registration, in the Contracting State of which the operator of the ship is a resident. 3. Profits derived by an enterprise of a Contracting State from the use, maintenance or rental of containers (including trailers and other equipment for the transport of containers) used for the transport of goods or merchandise in international traffic shall be taxable only in that State. 4. For the purposes of this Article, interest on investment directly 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. 5. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency .
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